A New National Response Framework

Yesterday FEMA announced the release of an updated National Response Framework (the fourth edition).  The most notable changes in this version of the NRF are the inclusion of Community Lifelines and a change to Emergency Support Function (ESF) #14.  Previously, ESF #14 was Long-Term Community Recovery.  With efforts to further engage and coordinate with the private sector in disaster response, ESF #14 has been changed to Cross-Sector Business and Infrastructure.

So what of Long-Term Community Recovery?  The National Disaster Recovery Framework (2016) outlines Recovery Support Functions (RSFs), which, at the federal level, are organized as coordinating structures along with the ESFs.  There are six RSFs, which generally align with the Core Capabilities for the Recovery Mission Area.  For anyone who has worked with FEMA in disaster recovery operations, you know these can be massive organizations, so why create an even large organization?  This structure should support the ESFs in focusing on immediate needs, while the RSFs can address long-term recovery.  When the Federal disaster response organization is initially set up for a disaster, the ESFs are immediately put to work to support state and local emergency needs.  In this phase, the RSFs are able to organize, gather data, and plan for eventually being the lead players as response transitions to recovery.  Recovery is very much a data-driven operation.  As this transition occurs, with the RSFs taking over, many of the ESF resources can be demobilized or tasked to the RSFs.

What does this mean for states and locals?  Fundamentally, nothing.  States simply need to have an appropriate interface with the new ESF #14.  Do states and locals need to mirror this organization?  No, and in fact most of the time when I see an organization centered around ESFs, I tend to cringe.  The ESF/RSF system works for the federal government because of the multitude of federal agencies that have responsibility or involvement in any given function.  Fundamentally, ESFs/RSFs are task forces.  Recall the ICS definition of a task force, being a combination of resources of varying kind and type.

Certainly, most local governments, aside from perhaps the largest of cities, simply don’t have this measure of complexity and bureaucracy.  It can work for some state governments, but for many it may not make sense.  Let’s consider ESF #1 – Transportation.  How many state agencies do you have that have responsibility and assets related to transportation?  In some states, like New York, there are many, ranging from State DOT, NYS Parks, the Thruway Authority, and the multitude of other bridge, road, and transit authorities in the State. Smaller states may only have a State DOT.  One agency doesn’t make a task force.  There are other options for how you organize your emergency operations plan and your EOC that can make more sense and be far more effective.  Essentially what I’m saying is to not mirror the way the feds organize because you think you have to.  All plans must be customized to YOUR needs.

On to the integration of community lifelines.  The goal of the new ESF #14 is to not only engage the private sector, but also coordinate cross-sector operations for stabilizing community lifelines.  I’m interested to see how this plays out, since the community lifelines are already addressed by other ESFs, so I suspect that once the new framework is tested, there may be some supplemental materials that come out to balance this.  That said, the integration of community lifelines is a good thing and I’m glad to see this gaining more traction and truly being integrated rather than existing as a good idea that’s never actually tasked.  Integration of community lifelines is something that every state and local government can at least track, if not take action on, depending on their capability and resources.  The updated NRF added some additional context to community lifelines, with information that supports integrating this concept into planning, response, and recovery.  I happen to appreciate this community lifeline focused timeline that is in the NRF.

While the focus of the NRF is on how the federal government will response, it is intended to be reflective of a whole community response.  It doesn’t necessarily provide guidance (nor should it) on planning, but it certainly serves as a reference.  Since it seems the feds are going all in on the community lifeline concept, I urge state, local, tribal, and territorial governments to examine how they can integrate them into your operations.  That all starts with planning.  It may begin as a function of situational awareness, but then what actions should a jurisdiction take when lifelines are impacted?  Even if a jurisdiction doesn’t have the capabilities to address the root cause, they still need to address the affects.

What thoughts do you have on the NRF update?

© 2019 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Musings of October – and the Crusade to End Bad ICS Courses

Last month sure was a busy one!  Much of the focus was on marketing for our company Emergency Preparedness Solutions.  I had the opportunity to meet a number of county and local government representatives in a reverse trade show in the Poconos and see some old and new faces at the Vermont Emergency Preparedness Conference.  Pictures of our booth are below.  I also had the opportunity to present with their State Training Officer on the State-Wide Emergency Management and Homeland Security Training Needs Assessment project we completed for the Vermont Division of Emergency Management and Homeland Security a few months ago.  We also need to congratulate Doug Babcock for being honored as Vermont’s Local Emergency Manager of the Year!

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While those trips were great, the highlight of the month was a trip to Toronto.  The impetus for the trip was the Emergency Preparedness staff of Public Health Ontario, who, after reading my blog posts on the necessity for improvements in Incident Command System (ICS) training, extended an invitation for me to sit in on some training they offer that came about from just that need.  The course I attended was Public Health Emergency Preparedness – An IMS-based Workshop.  Fear not – this is not a reinvention of ICS (or Incident Management System – IMS – as they refer to it in Canada), rather this is an enhancement to the current curriculum.

The Canadian provinces have each adopted curricula for their IMS which are near 100% mirrors of the ICS courses we use here in the States.  While in Toronto, I also had the opportunity to sit in for a bit on an IMS-200 course being conducted by the Toronto Office of Emergency Management.  They were great hosts and have made excellent enhancements to the curriculum for a Toronto-based audience.  (Thank you Sherry and Sarah!) The course offered by Public Health Ontario is truly workshop based, with little lecture and a lot of group work to walk participants through concepts of IMS.  The workshop is positioned between IMS-100 (which most took online) and IMS-200, and is public health focused.

While I’m often weary of discipline-specific courses in emergency management, since the essence of emergency management is cooperative, this workshop absolutely made sense.  Why?  Two big themes built the foundation for this… First, practitioners must be comfortable with their own sand box before they can play with the neighborhood kids.  Second, this particular application works for public health (and several other disciplines) because most of the public health response occurs at the population level, not necessarily at an incident site.  Because of this, public health will almost always function (at least the higher echelons of their incident management structure) from an emergency operations center or departmental operations center.  As such, it pays to invest some training time on a homogeneous audience.  That said, the scenarios that drove the workshop were in no way introverted only to public health concerns and the instructors encouraged thought and discussion toward other activities and associated agencies which would be involved in an incident.

With the positioning of this training between IMS-100 and IMS-200, Public Health Ontario has armed participants with better knowledge and familiarity of the IMS, allowing those who will progress through further (and multi-disciplinary) training a better perspective of how IMS is applied by public health which allows for a better understanding of the system itself.  Not only does the workshop address some internal incident management training needs for public health, it also addresses some of the issues I’ve mentioned previously with ICS training as a whole.  The workshop is expertly designed by the Emergency Preparedness team at Public Health Ontario, and embraces concepts of adult educational methodology which we need to pay more attention to.  The high level of interaction lends to improved transfer of knowledge and better outcomes.  They included information such as the phases of emergency management and the need to reference deliberate planning efforts such as Emergency Operations Plans (EOPs) and Continuity of Operations Plans (COOPs).  This is certainly something we don’t have enough of in ICS courses yet is critically related.  Do you think the majority of our attendees know what these are, much less what is in theirs?  Guess again!

More information on this workshop can be found at https://www.publichealthontario.ca/en/About/Departments/Pages/Incident-Management-System-for-Public-Health.aspx.  Many thanks to Moira, Richard, and Evanna for the invite and the hospitality!

With my road trips complete, I am returning back to the normal pace of work and preparing for another graduate course which begins next month.  I’ve also considered the need to ramp up my concern on this matter of poor ICS curricula from an occasional rant to a crusade.  This is a matter of public safety – from a sociological perspective there is nothing more important than our ability to effectively respond to save lives, stabilize the incident, and preserve property.  Let’s make some changes!

As always, many thanks to my readers; and if you are with a government entity, not for profit, or private interest that is seeking consulting services in the areas of emergency and disaster planning, training, exercises, and anything in between, please feel free to contact me.

© Timothy Riecker

Emergency Preparedness Solutions, LLC

What Planning Format To Use?

Comprehensive Preparedness Guide 101 (CPG 101) describes three format options for your emergency operations plan (EOP): The traditional functional EOP format, the Emergency Support Function (ESF) format, and the agency/department focused format.  As mentioned in CPG 101 the traditional functional EOP format is the most popular and widely used.  It generally provides for three major sections – the basic plan, functional annexes, and hazard specific annexes.  The traditional format provides for the greatest flexibility and allows a jurisdiction or organization to easily evolve their plan as the need for addressing additional issues or hazards is recognized.  Continuity of Government/Continuity of Operations (COG/COOP) plans are easily integrated as annexes as our newer concepts such as resiliency plans and climate change plans. 

Agency/department focused EOP formats provide utility for those folks that like to crack open the book looking to answer the question ‘what is expected of me?’.  This format offers some flexibility, but under most occurrences where the need to address a new issue arises edits need to be made through much of the plan to identify and address each agency’s involvement in said issue.  It can also be awkward to include other associated plans, such as the afore mentioned COOP and COG plans.  It does work for smaller communities, though, whose hazards and other planning areas stay fairly static. 

The ESF EOP format is modeled after the National Response Framework (NRF) (originally the Federal Response Plan) which addresses functions by grouping agencies and organizations with responsibility and resources to address those functions.  This model has worked fairly well for the federal government given their structure and the general federalist approach of most agencies (aside from those agencies with direct authorities such as the US Coast Guard).   There is some flexibility in this model with the ability to include both support and hazard specific annexes, but one must be cautioned not to confuse the ESF annexes with the support annexes.  The key word in the format is ‘support’, which is largely what the federal government does in response to a disaster. 

Last week Lucien Canton posted an article Emergency Support Functions: Misunderstood and Misapplied.  Read this!  As usual, Lu states his point expertly as he discusses the pros, cons, and uses for the ESF structure.  Many jurisdictions, in an effort to mirror a system which seems to work for the federal government, create their EOP in an ESF format.  I’ve rarely ever seen it well applied – at least not in the form that the feds use.  Understanding that the feds structure their ESFs to address policy and coordination, these same needs may not exist at a state or local level.  Therefore states and locals change the ESF structure.  While there is certainly no requirement to use only those ESFs which are used in the NRF, using a different format can cause great confusion.  For example, what is ESF #12 (Energy) in the NRF may be an ESF for economic recovery for a city or county.  Now we have what we’ve been trying to avoid in incident management – a lack of common terminology. 

Each jurisdiction and organization should choose which format works best for them.  I would strongly recommend the traditional format which is the easiest to shape to meet your needs rather than trying to work within an awkward planning framework.  Remember that no plan is ever perfect, but requires regular attention to ensure that it evolves with and addresses your needs.  Don’t try to tackle it all at once, either, or on your own.  Proper planning is a team effort requiring input from multiple stakeholders in your jurisdiction or organization.  CPG 101 references ‘whole community’ planning which is a great idea to ensure that you capture multiple perspectives and that all stakeholders are bought into the process and the product.  Take on your planning work in small bites, one component at a time.  First work on the base plan – the most essential part.  Then identify those functional and hazard specific annexes which are most important – accomplish those next.  To help guide your work it will help to create a project chart for your planning efforts identifying timelines and benchmarks, stakeholders, and needed inputs.  Finally, don’t forget to exercise your plans to validate them! 

Lastly, my marketing plug – If you need help planning please contact Emergency Preparedness Solutions!  EPS is experienced in working with governments, private sector, and not for profits in all facets of preparedness including assessment, planning, training, and exercises.  We are happy to discuss your needs and determine the best way to meet them. 

What planning format do you prefer and why?

© 2014 – Timothy Riecker

 

 

 

Creating Operational Emergency Plans

I was inspired for this article from an email I received earlier today from Lu Canton, a rather prolific emergency management consultant who has branched a bit into consulting consultants.  His email today (a forward from his blog) was about making emergency plans ‘real’.  His point was that many planners focus on checking the boxes of the list of planning requirements (those prescribed by law, regulation, etc.) rather than focusing on ensuring that you have a plan that can actually be implemented.  He conducted a webinar over a year ago which I had blogged about.

Planning requirements are important, as they largely stem from lessons learned from earlier incidents.  Granted, some of these requirements come about being translated through the eyes and ears of politicians whose staffers write the legislation and don’t understand emergency management at all – resulting in convoluted, contradictory, and poorly focused requirements.  Requirements lead to standards, helping to ensure that emergency managers are addressing the needs of their jurisdiction and best practices in the industry.  To help guide us through this, many higher level agencies provide templates.  I’ve pontificated in the past about the danger of templates, which have a place in reminding us of these requirements and help us with format and flow, but are often misused by individuals who simply seek to fill in the blank with the name of the jurisdiction and claim they have a finalized plan.

How do we avoid falling into this trap?  Follow the planning process!  FEMA’s Comprehensive Preparedness Guide (CPG) 101 provides an overview of this process for creating emergency operations plans.  The two initial steps – forming a planning team and conducting a hazard analysis – are absolutely critical to the integrity of the process and ensuring a quality plan that meets the needs of your jurisdiction by addressing your threats and hazards.  Planning teams then need to consider these threats and hazards, make reasonable assumptions about their impacts (using a credible worst case scenario), then identify resources and strategies the jurisdiction will undertake to solve the problems they will face.

Does all this mean that a plan needs to be written from scratch?  Of course not!  In fact I strongly encourage people against it.  It’s practically guaranteed that you will forget a critical element.  One of the greatest things in the emergency management community is how we learn from each other.  You can reference templates you find, examine plans of your neighboring jurisdictions or jurisdictions similar to you, check out what is on LLIS.  There is plenty of great content you can examine and apply for your own use.  Just ensure that you carefully review and consider how it applies to you.

As you write the plan, think the details through.  This will help ensure that your plan is operational, not just meeting requirements.  Discuss with your planning team what is expected of each assisting and cooperating agency for each incident type.  Who will be in charge?  What resources will be necessary and where will you get them from?  What would the objectives be and what processes and decision points must be conducted to accomplish those objectives.  As you create the plan, map out these processes and ensure that you’ve considered the who, what, where, when, and how of each step in each process.  Recall that you are planning at a strategic level, not a tactical level.  Planning at a tactical level is nearly impossible with a pre-incident (aka ‘deliberate’) plan.  Tactics will be addressed during the actual response, hopefully referencing the EOP/CEMP you are writing now, and implemented through an incident action plan (IAP).

Remember, though, the proof is in the pudding, as they say.  Your plan needs to be tested to ensure viability.  Use a table top exercise to test policy and decisions, then a functional exercise to test the implementation of the plan and higher level tactics.  Full scale exercises and drills can test the tactical implementation of plans.  Good evaluation of the exercises will lead to planning improvements.  For insight on the exercise process, you can check out my exercise management series of posts referenced here.

Remember: when it comes to planning – keep it real!

Tim Riecker