Canton on Emergency Management

Why Your Emergency Plan Will Fail: Ignoring Inclusiveness

Some years ago, I was tasked with reviewing the evacuation plan for a large metropolitan area. The plan looked pretty good and seemed to address all the critical issues. Things began to fall apart quickly when I started asking questions about how the plan was developed. It turned out that the plan had been written by a single individual in two weeks on the orders of his department head. None of the agencies tasked to support the plan were aware of it or had ever been consulted. In addition, the plan effectively ended at the county line; none of the adjacent counties had been consulted as to how they would support a major evacuation. The plan was well written but totally worthless, the classic example of a “paper plan.”

This is an extreme example of failing to include stakeholders in the development of an emergency plan. Few planners would fail to include coordination with other agencies in their plans. However, these same planners frequently neglect to include non-response-oriented stake holders in their planning process.

The first time I recommended a declaration of emergency to our mayor in San Francisco, the process almost suffered a significant delay when the City Attorney’s staff insisted on reviewing the standard format included in the emergency plan. It seems they had never been consulted on the plan and new nothing about the declaration process or recovery programs, despite the city still being heavily involved in recovery from the Loma Prieta earthquake. Within a few weeks, we had designated attorneys assigned to our EOC team who received training in emergency management legal issues. Other examples of frequently neglected agencies that we worked with are the risk manager (risk analysis and insurance issues), the personnel department (personnel reassignment, volunteer management, union issues), and the department of the environment (holistic recovery issues).

As neglected as non-response agencies are, the situation is even worse when we consider community organizations. The big-name organizations, such as the Red Cross and Salvation Army, are generally included but lack of input from other community-based organizations can lead to significant problems in a disaster. One of our most embarrassing lessons learned from Hurricane Katrina was that the planners who developed emergency supply lists had completely neglected to include items for women such hygiene products and supplies for nursing mothers. In 2011 the City of Los was found liable for failing to include people with functional needs in their emergency planning. Other issues that have emerged are often related to cultural norms such as those surrounding the handling of remains. Even food can be an issue: I learned the hard way that there is a significant difference between long grain and short grain rice when a vendor shipped the wrong type to several Pacific islands during a typhoon relief operation.

Inclusiveness is of critical importance in emergency planning. But what does that really mean? I often get pushback from planners that “we can’t include everybody”. This is based on the erroneous assumption that all stakeholders are equal. Being included does not necessarily mean that everyone gets a vote and veto rights. What it does mean is that all stakeholders should be able to have input to the planning process and have that input at least considered as the plan develops. This can be accomplished in many cases by providing an opportunity to review working drafts and to comment on those drafts. The key to success in that their input must be acknowledged and responded to, even if the issues raised will not be addressed in subsequent drafts. Providing an explanation as to why input will not be included may not always defuse conflict, but it will at least allow discussion based on fact rather than generating a feeling the stakeholder is being ignored.

There are many reasons an emergency plan may fail but not including input from those who will have to implement the plan and those affected by it is a guarantee of failure.

Why Your Emergency Plan Will Fail: Sequential Planning

The development of the Comprehensive Emergency Management model by the National Governors’ Association in 1979 was a major step forward for modern emergency management. It was the first attempt to define emergency management in a holistic way that integrated the various functions related to disaster. It influenced the development of FEMA and forms the basis for much of our current emergency management practices.

Unfortunately, it has also created some problems for emergency planners. In using the term “phases” the framers of the CEM document were referring to clusters of  “emergency-related activities…that are related by time and function to all types of disasters.” This was an attempt to group categories of like activities to identify relationships among them. It was not an attempt to define how disasters unfold.

Why is this a problem?  Approaching a disaster with a preconceived idea of how it will progress can lead to poor decision making through cognitive biases such as confirmation or overconfidence biases. It can lead to confusion if phases are used as operational triggers that generate competition for resources and conflict over leadership roles.

Disasters do not operate in phases. Consider mitigation, for example. While the CEM model would suggest that mitigation is a phase between recovery and preparedness, there are immediate mitigation activities that take place in a disaster, such as reduction of immediate hazards or assessment of the performance of past mitigation projects. Similarly, decisions and activities conducted during the initial stages of response such as route restoration and debris clearance can have an impact on recovery operations, particularly in relation to insurance issues.

Perhaps the biggest problem I have seen in a commitment to a sequential approach to disasters is the tendency to develop separate plans for each phase. I’m not suggesting that separate plans are the problem. Quite the opposite is true as the planners, implementers, required skills, and strategies for each phase are quite different, as is the level of public involvement. The problem is that because each plan requires different working groups, they tend to be created in a vacuum with an underlying and often unspoken assumption that each plan will be implemented in sequence. The result of simultaneous implementation is invariable a competition for resources and confusion over leadership and priorities.

The solution is simple but complex in execution. You need to look at response to a crisis not in phases but as a series of activities that occur over the life cycle of the disaster. This includes particular attention to priorities for resources and transition of operational leadership. You can’t make a crisis fit into your preconceived notion of phases; you need to adapt to the unexpected. There’s a reason “Flexible” is one of the Principles of Emergency Management.

Why Your Emergency Plan Will Fail: Ignoring your target audience

Many years ago when I was a student, there was an apocryphal rumor making the rounds about a teacher who used the “fling method” to grade term papers. The method involved standing at the top of a staircase and flinging the papers towards the bottom. The theory was that those papers containing the most content (i.e., the most pages) would travel the farthest. Where your paper fell on the staircase determined your grade. I suspect that many emergency managers are using this method to determine the value of their emergency plans.

We all deride “doorstop plans,” plans that come in 4-inch binders or multiple volumes. Yet we continue to produce them. However, both anecdotal evidence and a small smattering of research suggest that during a crisis no one is going to read your emergency plan. This begs the question, for whom are we writing the emergency plan?

In my previous blog, I wrote about the three levels present in any response (strategic, operational, and tactical) and the need to distinguish among these when writing your plan. The easiest way to do this is to ask the question, “who is my target audience?”

Consider, for example, what happens when we apply this concept to the basic plan. The basic plan is a bit of an exception in that it delineates overall strategy and lays out the operational framework for response. But who is the target audience? If you’re honest, you’re probably writing it for anyone but the user (e.g., auditors, evaluators, politicians, the public) with the intent to demonstrate your level of preparedness. Plan users are most likely intimately familiar with the contents as it is the basis for more detailed planning. If this is indeed the case, why include extraneous material that is of no use to anyone?

Let me give an example of what I mean by extraneous material. Almost every basic plan I have reviewed over the years contains an extensive section on the Incident Command System. Given our requirements for ICS training, how likely is it that someone reporting to the emergency operations center in a crisis will be completely unfamiliar with ICS? Even assuming that they are, will they have any inclination to sit down and read several pages of ICS theory before starting work? Now consider the non-responder who is reading your plan for background; do they really need an in depth explanation of ICS? I suggest that in both cases, your audience might be better served by a single page fact sheet rather than five to ten pages of information.

We find a similar problem when we consider the supplementary annexes in the emergency plan. Here the problem is that we tend to mix operational and tactical information. Let me stress again that the target audience of the emergency plan is at the operational level. Annexes are about relationships, priorities, and specific assignments. They are not step by step instructions on how to perform a task. The emergency plan is a toolbox, not a bible; it should tell the reader what they are expected to do, what they will need to do it, and the resources that are available. It should not have to tell them how to do it.

Next time you’re reviewing your emergency plan, ask the question, “who’d my target audience?” Identify what they need to get their job done and cut out anything extraneous. The shorter the plan, the easier it will be for the user to find the information they need. Shorter is better; you’re not being graded by the “fling method.”

Why Your Emergency Plan Will Fail: Ignoring Basic Concepts Part 2

In my last post I stressed the importance of applying basic concepts to developing your emergency operations plan, particularly distinguishing between response generated and agent generated needs. Another important concept is that of operational levels.

There are roughly three levels in any response to crisis. The first and most obvious is the tactical level, those actions that directly address the crisis. The next is the operational level that provides support to the tactical level. The final, and most neglected, level is the strategic, where the long-term impact of the crisis is assessed, long range goals are identified, and policies are developed. In simple terms, the strategic level sets the policy direction, the operational manages the overall response, and the tactical implements the actions necessary to achieve the desired results.

Why is this concept so important to planning? It’s because each level has unique planning requirements. Information requirements, operational focus, and even operating structures will vary and a plan that is appropriate for one level may prove ineffective for another.

The tactical level requires very specific planning. Leadership is primarily hierarchical, with decision making centralized in a single command function. Information requirements to support decision making are specific and the more granularity the better. The event horizon is often minutes or, at most, a few hours.

Contrast this with the operational level. Unlike the tactical level that seeks to address an immediate problem, the operational level seeks to jump ahead of the crisis and address anticipated needs. The event horizon is hours and days, and, on occasion, may be even longer. Information requirements focus more on analysis and projections, seeking to understand the “big picture”. Leadership is more about coordination and less about command and control, with decision making being more collaborative.

Where the operational level focuses on anticipated support to the immediate response, the strategic considers the long-range impact of the crisis. The focus is on community restoration and long-term recovery. Information requirements tend to focus on potential changes to demographics, housing, transportation, and the economy. Decision making may require community involvement and extend over years.

What does all this have to do with your plan? Understanding the different operational levels and their different demands for information, anticipated timelines, and leadership structure allow you to structure components of you plans to address these specific needs. For example, the level of information required by an on-scene incident commander may be too detailed to meet the needs of the operational or strategic levels. Conversely, the long-range analyses and forecasts needed by the strategic level would be of no use to the tactical. Similarly, the type of collaborative leadership demanded in the higher levels might have grave consequences if applied to the tactical level where immediate decisions are the norm.

The principal failure I find related to operational levels is the assumption that everything must be contained in a single plan. The typical emergency operations plan is operational in nature. Let me say that again: emergency operations plans are operational level plans. They are intended to coordinate the activities of the plan signatories in support of tactical operations. The basic plan summarizes relationships among the signatories and annexes delineate specific tasks as they’ve been agreed to, but the plan must be supported by lower-level documents that address tactical issues.

Trying to cram too much information into your emergency operations plan creates a bulky and unwieldy document that makes it hard to find necessary information. It almost guarantees that your plan will not be used when it is most needed.

Why Your Emergency Plan Will Fail: Ignoring Basic Concepts Part 1

While emergency plans will never be classified as great literature, like any good novel, they should have a narrative flow. That is, they should have a logical progression that is easy for the reader to follow. This allows the reader to understand the intent behind the plan and to quickly locate needed information.

Unfortunately, many of the plans I review are confusing and lack coherency. This is often the result of ignoring basic emergency management concepts during plan development.

One of the most basic concepts, which I believe was formulated originally by E.L. Quarantelli, is recognizing that disaster response actions can be divided into two categories: response-generated and agent-generated.

Response-generated actions are generic and tend to be performed in roughly the same way in most response operations. For example, a fire department responding to a structural fire will generally approach each fire in the same way. On-scene tactics may vary but standard operating procedures will govern the overall response.

Agent-generated actions, on the other hand, are specific to the hazard that has caused the disaster. These actions represent a departure from the usual methodology and are often unique to the specific hazard. A fire department faced with a major conflagration, may opt to use tactics that run counter to normal SOPs, such as switching from saving individual structures to creating firebreaks, limiting response to other alarms, or activating mutual aid.

What does this mean to your planning? Simply put, response-generated actions can be largely preplanned. It is possible to identify lead and support agencies, tactics, potential staging areas, etc. In short, the bulk of your emergency plan consists of pre-planning for response-generated needs. This creates a “toolbox” of potential resources that can be modified or redirected depending on the crisis. In very simple terms, you identify specific needs and assign the appropriate resource.

Agent-generated actions, on the other hand, are essentially contingency plans for specific hazards. They tend to be very specific and highlight the differences between “normal” response and response to a specific hazard. This may be reflected in revised assumptions or may contain specific instructions to responding agencies, in essence a rough draft of the initial action plan. An example would be a hazard-specific annex or plan that addressed flooding in a specific location. This annex or plan might show the anticipated location of the command post and staging areas, evacuation routes, etc. Anything not addressed in the annex or plan would be assumed to follow the guidance for response-generated needs. In this example, sheltering down outside the flood zone would follow the plan for this response-generated action.

Why is this concept important? Mixing the two sets of actions can lead to confusion. Some parts of the plan may contain too much detailed information while other parts do not have enough. Responsibilities can be muddled, and the wrong tactics may be implemented. More importantly, understanding this concept emphasizes the importance of knowing your risks. This allows your hazard-specific annexes to identify critical differences from your basic plan and supporting annexes and address them without duplicating effort. The result is a more coherent plan that is easier to understand and implement.

Why Your Emergency Plan Will Fail: One-size-fits-all Planning

In my many years as a consultant, I have had the opportunity review quite a few emergency operations plans. One of the most common tasks I am asked to perform is to ensure that the EOP is conformant to the guidance in CPG 101 Developing and Maintaining Emergency Operations Plans . The one thing that I am never asked is whether I think the plan will work. Sadly, in many cases, my answer would be, “no.”

There are any number of reasons a plan will fail. In fact, one of my most popular presentations is devoted to this particular  topic. Rather than cram everything into a single “top ten” post, I thought it might be more productive to write a series of posts on some of the key reasons that could lead to failure of your plan in a crisis.

Heading my list of potential problems is blind acceptance of the format guidance offered in CPG 101. This frequently produces what  Dr. Erik Auf der Heide refers to as the “paper plan syndrome,” a situation where the mere existence of a plan is equated with preparedness. Sociologist Lee Clarke makes a similar point, noting that many plans are used as symbols to demonstrate that authorities are in control of a situation when just the opposite is true. The late Enrico Quarantelli put even stronger, “One of the greatest impediments to disaster preparedness is the tendency to believe that it can be accomplished merely by the completion of a written plan.”

In recent articles in my newsletter, both my colleague, Tim Riecker, and I stressed the need to make sure your plan is based on the needs and capabilities of your organization. One-size-fits-all planning almost guarantees that the resulting plan will not be aligned with those requirements. Slavishly following CPG 101 does not automatically guarantee success and can even be a barrier to it.

“But we’re required to follow CPG101!” I hear you say. My suggestion is that you re-read the guidance. “The goal of CPG 101 is to assist in making the planning process routine across all phases of emergency management and for all homeland security mission areas.” I’ve italicized the words “planning process” because this is what CPG 101 is really intended to do: improve your ability to develop effective plans and it does it well. The bulk of the document is devoted to this. A process that is collaborative and inclusive and that considers organizational needs and capabilities is ultimately more important than plan format. Establish the process and the plan will follow.

One final word on formats. Here’s the word from CPG 101, ”FEMA does not mandate a particular format for EOPs. In the final analysis, an EOP’s format is acceptable if users understand it, are comfortable with it, and can extract the information they need.” So, throw out the templates, stop copying the formats out of CPG 101, and think about what your plan should look like to be effective.

More to follow!

Are You Wasting Your Time With ESFs?

In a recent article ESFs Aren’t for Everyone, my colleague, Tim Riecker argues against the use of the Emergency Support Function (ESF) system for local emergency operations centers (EOC). As someone who was in almost at the adoption of the ESF system by FEMA, I wholeheartedly concur with Tim’s assessment.

To provide a bit of context, the ESF concept was developed just prior to the Loma Prieta earthquake by FEMA Region IX to coordinate decentralized federal operations following a major earthquake in the San Francisco Bay region. The plan was for each federal agency to perform its assigned mission independently on the assumption that communications would be disrupted and central coordination sporadic. The concept was never implemented as planned, instead defaulting to coordination via the Regional Operations Center and the Disaster Field Office. The ESF concept was later adopted for general use by FEMA in all disasters.

The problems began as FEMA moved towards adoption of the Incident Command System and attempted to merge the two systems in the years following Hurricane Iniki. ICS was developed specifically for to facilitate centralized coordination of response activities by agencies that were primarily hierarchical in nature. ESFs, as Tim points out, while capable of providing immediate response support, also have primary recovery missions. For example, the primary mission of ESF 2 Communications is the restoration of communications infrastructure. Immediate response support is secondary to this mission. Communications support to the operations center is generally handled by a separate team in the Logistics Section. This conflict in focus means that merging ICS and ESFs is an exercise in futility. I know this from personal experience.

This is not to say that either system is wrong. ESFs are an excellent planning tool as they can bring together the various resources required to address a particular need. However, even at the federal level the system is not implemented as written. There are no multi-agency teams in each ESF. Instead, you’ll find anywhere from a single representative to a small team from the lead agency, sometimes representing more than on ESF. If a support agency is needed, the request is passed to the person representing that agency as the lead in a different ESF. The relationships and pre-planning are important, not the operating structure.

The Incident Command System has also been proven to be a highly effective system. However, the problem I have found is the tendency to over structure EOC management teams. I find that there is a tendency to confuse the overall organization chart for the community with that of the team required to coordinate activities in the EOC. Like ESFs, what’s printed in the emergency plan is not what actually occurs in the EOC. In applying ICS, commitment to ICS principles is important, not the operating structure. Determine your needs and build your EOC management team accordingly.

Like Tim, I recommend against using ESFs in the EOC. I believe they are good planning tool but a poor operational one. There are no mandated operating structures for your EOC; you don’t have to use ESFs. If you are committed to ICS principles and focus on accomplishing the core functions (command, finance/admin, operations, planning, and logistics) you have a lot of latitude to build an operating structure that works for your jurisdiction. There are no “correct” operating structures, only  those that work and those that fail.

I hear what you want, but is it what you need?

In a recent email, consultant Alan Weiss wrote, “One of the primary flaws of unsuccessful consultants is that they accept client wants as the real need.” Weiss points out that merely giving the client what they want does not offer much value to the client. Instead, suggests Weiss, we need to probe deeper to find the underlying need that prompted that want.

Confusing want and need is a fairly common problem with clients. I’ve lost track of the number of times I have been asked to write a plan or facilitate an exercise only to find that my client lacks the underlying program to support these activities. I was once told during a debrief for a project for which I was not selected that my proposal looked like I expected the client to do some work because I had proposed several planning workshops. I remember one exercise whose objective was to test a new emergency plan where the plan had never been distributed to the participants. Then there was the evacuation plan I was asked to review that had been written by a single individual and never coordinated with any of the agencies tasked to support the plan. In each case, what the client wanted (a plan, an exercise, an annex) was not what they needed.

Unfortunately, some emergency managers let themselves be driven by factors such as grant requirements or federal guidance rather than taking the time to determine what they really need. They fail to understand that grants and guidance are not drivers of your program but rather opportunities to enhance it. Here are some ways you can do this:

1. Use standards, particularly the Emergency Management Accreditation Program (EMAP) Standard. Standards provide a baseline against which you can measure your program. While EMAP will not evaluate your operational capabilities, it can strengthen the underlying administrative base on which your program depends.
2. Develop strategies, not plans. Too many plans merely regurgitate federal guidance without considering how that guidance must be modified to meet local conditions. One size does not fit all when it comes to emergency planning. One of the things I do in reviewing a plan is to analyze all the tasks assigned to various agencies; I almost invariably find that there are not enough personnel resources available to support the plan. Develop an effective strategy first, then build your plan around it.
3. Develop a strategic plan. The strategic plan is a road map that helps achieve your goals over time. With this roadmap, you can decide how best to use grant funding and incorporate new guidance and best practices.
4. Use exercises as planning tools. Each type of exercise has its place in improving your capabilities. However, they are frequently considered "final exams" given at the end of a planning cycle. But they can also As a consultant, I have found that discussion-based exercises can be highly effective planning tools by fostering open discussion based on strategy.

Understanding the difference between want and need is critical if you want to maximize limited resources. If you’re not clear about what you need to achieve, you’re spinning your wheels and likely wasting your money.

Equity In Emergency Management

“Equity” is a term that has become more and more common over the last few months. It refers to the need to ensure that all members of society are treated equally by eliminating inherent biases. In particular, the discussions on biases inherent in the delivery of government services are both appropriate and necessary and emergency management is in exception.

On the surface, this seems like a no-brainer. In my experience, emergency managers are committed to delivering services to disaster victims without regard to considerations such as gender, race, or immigration status. However, as with most things, the reality is more complicated.

Experience and research both show that disasters do not impact all segments of a community in the same way. Marginalized groups such as those with special needs or in low-income populations are disproportionately affected by disasters. Since our focus is on those with the greatest need, one would expect that these victims would be the priority and that this would in turn assure equity in the distribution of disaster assistance.

Unfortunately, this is not the case. Research by Dr. Junia Howell and others suggests that federal disaster aid tends to increase wealth inequity in affected communities. Federal disaster relief policies are not intentionally designed to be unfair but their emphasis on avoiding fraud and improper payments create rigid requirements that can be difficult for the economically disadvantaged to meet. Even something as simple as access to a computer can create a barrier to assistance.

Another issue is the emergency management maxim of “do the most good for the most people”. While the public assumes that governments have unlimited resources with which to respond to disaster, emergency managers are very conscious that resources may be limited, particularly in the early stages of a disaster. This means that we are often faced with hard ethical decisions about how and where to apply limited resources.  This concept of triage, to borrow the medical term, is based on the assumption that scarce resources should be allocated to those requiring the least assistance, thereby assisting more people, and not necessarily those in the most need. People who place an increased demand on those resources, such as those with an inability to self-evacuate are at risk of being marginalized. Consider, for example, the issues surrounding evacuation in Hurricane Katrina.

As I stated earlier, the discussion on equity is an important one and emergency managers should not shy away from it. Creating equity will require not just consideration of how we do outreach or ensuring that everyone gets the same amount of assistance. Instead, it will require a fundamental reevaluation of disaster policy and a movement away from our “one-size-fits-all” approach to services and fixation on fraud.

Thoughts on Emergency Management

Two questions that I am frequently asked these days are what significant changes I have seen in emergency management in my some 40-odd years and what I think the future holds. That’s a little bit of a moving target as one of the things I have enjoyed about emergency management is that it is constantly evolving.

Without a doubt, the most significant change, as Tom Drabek noted in Major Themes in Disaster Preparedness and Response Research has been the increased professionalization of local emergency managers. When I was introduced to the emergency management, we all came with previous experience, primarily military or first responder disciplines. You learned your business on the job, and, in retrospect, we sometimes learned the wrong lessons.

I think that catalyst for change has been twofold: role of the Federal Emergency Management Agency in developing doctrine and best practices but, more importantly, the rise of emergency management as an academic discipline. One of the hallmarks of a profession is a specialized body of knowledge. For a long time, we were content to allow ourselves to be defined by the tasks we coordinated, most of which were performed by others. This technical knowledge was useful and important, but it was hardly unique to emergency management. It wasn’t until we came to recognize and accept the vast amount of research on disaster behavior that we began to truly understand the role we could play in developing strategy and coordinating complex response.

Another significant development, which I believe you can attribute to acceptance of disaster research, was the expansion of the role of the emergency manager beyond response operations. While many of us are still locked into the role of responders, there is a growing awareness that strategic issues such as mitigation and recovery planning is where we can make the most impact. Community risk goes beyond just natural hazards, and we have an expanded role to play in other areas as well. As evidence of this, we need look no farther than the role FEMA and local emergency managers are playing in supporting COVID response.

Where do we go from here? There’s still a lot of work to do in adequately defining who we are and what we do. It wasn’t until 2007 that we had an accepted definition of emergency management and the Principles of Emergency Management. The Principles were always intended to be just a starting point, but it is only recently that there is interest in reviewing and revising the Principles. We have a rigorous certification in the Certified Emergency Manager designation from the International Association of Emergency Managers, but it is not yet a base requirement for higher level emergency management positions as certifications are in other professions. We still lack a competency framework that defines minimum requirements and standards for emergency management positions. The same holds for a code of ethics, a project that my colleague, Carol Cwiak at North Dakota State, has been championing for years. Without these things, it is difficult to call ourselves a profession.

I think the future of emergency management is bright. We have a new generation of emergency managers emerging, one that is better educated and conversant with disaster research. We have the support of a strong academic community that is building the specialized body of knowledge that underpins our profession and is developing the curricula that are educating the new generation of emergency managers. FEMA, despite setbacks, has made steady progress in developing doctrine. Yes, there is still much to be done but it's worth reflecting on how far we've come.