Last month I got to spend several days with some great international colleagues discussing problems and identifying solutions that will hopefully have a meaningful and lasting impact across incident management and emergency response. No, this wasn’t at an emergency management conference; this was with an incredible group of ICS subject matter experts convened by ICS Canada, with a goal of addressing some noted gaps in ICS doctrine, training, and other related documents. While the focus was specific to the documents under the purview of ICS Canada, most of these matters directly apply to ICS in the United States as well.
Overall, our doctrine, curriculum, etc. (collectively, documents) across ICS is a mess. Broadly, the issues include:
- Poor definitions of key concepts and features of ICS.
- Lack of proper emphasis or perspective.
- Lack of inclusion of contemporary practices. (management concepts, social expectations, moral obligations, even legal requirements, etc.)
- Lack of continuity from doctrine into supporting documents and curriculum. – Everything needs to point back to doctrine. Not that every tool needs to be explicitly included in the doctrine, but they should be based upon consistent standards.
- A need to support updated training to improve understanding and thus implementation.
As we discussed among the group and I continued thought on this, I’ve realized that ICS, as it relates to the US (NIMS) has so little doctrine spread across a few NIMS documents (the core NIMS doctrine, National Qualification System documents, and a few guidance/reference documents – which aren’t necessarily doctrine). In the US, via the National Wildfire Coordinating Group (NWCG), we used to have a whole array of documents which could be considered ICS doctrine (in the days of NIIMS <yes, that’s two ‘eyes’>). When the responsibility for the administration of ICS (for lack of better phrasing) shifted to DHS, these documents were ‘archived’ by the NWCG and not carried over or adopted by the NIMS Integration Center (NIC) in DHS who now has responsibility for NIMS oversight and coordination. The NIC has developed some good documents, but in the 20 years since the signing of HSPD-5 (which created and required the use of NIMS) it seems the greatest progress has been on resource typing and little else.
Looking at current NIMS resources, I note that some are available from the core NIMS site https://www.fema.gov/emergency-managers/nims while others are available from EMI at https://training.fema.gov/emiweb/is/icsresource/. All these documents really need to be consolidated into one well organized site with doctrine identified separate from other resources and documents (i.e. job aids, guidance, etc.).
I thought it might be fun to find some examples so I decided to open up the ICS 300 instructor guide, flip through some pages, and look at a few concepts identified therein that might not have much doctrinal foundation. Here’s a few I came up with:
- Formal and Informal Communication
- These concepts aren’t cited anywhere in NIMS documents. While superficially they seem to be pretty straight forward, we know that communication is something we constantly need improvement in (see practically any after-action report). As such, I’d suggest that we need inclusion and reinforcement of foundational communications concepts, such as these, in doctrine to ensure that we have a foundation from which to instruct and act.
- Establishing Command
- This is mentioned once in the core NIMS doctrine with the simple statement that it should be done at the beginning of an incident. While often discussed in ICS courses, there are no foundational standards or guidance for what it actually means to establish command or how to do it. Seems a significant oversight for such an important concept.
- Agency Administrator
- While this term comes up several times in the core NIMS doctrine, they are simple references with the general context being that the Agency Administrator will seek out and give direction to the Incident Commander. It seems taken for granted that most often the Incident Commander needs to seek out the Agency Administrator and lead up, ask specific questions, and seek specific permissions and authorities.
- Control Objectives
- Referenced in the course but not defined anywhere in any ICS document.
- Complexity Analysis
- The course cites factors but doesn’t reference the NIMS Incident Complexity Guide. Granted, the NIMS Complexity Guide was published in June 2021 (after the most recent ICS 300 course material), but the information in the Complexity Guide has existed for some time and is not included in the course materials.
- Demobilization
- Another big example of the tail wagging the dog in NIMS. Demobilization is included across many ICS trainings, but there is so little doctrinal foundation for the concept. The core NIMS doctrine has several mentions of demobilization, even with a general statement of importance, but there is no standard or guidance on the process of demobilization beyond what is in curriculum – and training should never be the standard.
For ICS being our standard, we haven’t established it well as a standard. A lot of work needs to be done to pull this together, fill the gaps, and ensure that all documents are adequately and accurately cross-referenced. This will require a significant budget investment in the National Integration Center and the formation of stakeholder committees to provide guidance to the process. We need to do better.
What doctrine and document gaps do you see as priorities in NIMS?
© 2023 Tim Riecker, CEDP
The Contrarian Emergency Manager 