Natural Hazards Observer
| July 2004 | Volume XXVIII | Number 6 |
Invited Comment
The National Response Plan:
Process, Prospects, and Participation
The Homeland Security Act of 2002 and Homeland Security Presidential Directive 5 (HSPD-5) "Management of Domestic Incidents," issued in February 2003, set the wheels in motion for the creation of two essential frameworks that will form the underpinnings of the nation's approach to incident management for the foreseeable future. These documents are the National Response Plan (NRP) and the National Incident Management System (NIMS). In a few months, NRP will be approved by the Homeland Security Council and 180 days later it will become national policy. The NRP and its companion NIMS will fundamentally change how the U.S. prepares for and responds to extreme events.
Impetus
In February 2003, the administration began the process of creating a nationwide template for federal, state, local, and tribal governments and private sector and nongovernmental organizations to work together effectively and efficiently to prevent, prepare for, respond to, and recover from domestic incidents regardless of cause, size, or complexity. The motivating ideas were to focus national incident management policy on terrorism, in particular to integrate emergency management, law enforcement, and public health; to establish the U.S. Department of Homeland Security (DHS) as the agency responsible for domestic incident management; and to de-conflict and integrate existing federal plans.
The NRP creates a new national approach to domestic incident management by merging and integrating key concepts from existing "major" federal response plans, such as the Federal Response Plan (FRP), the Federal Radiological Emergency Response Plan (FRERP), the National Contingency Plan (NCP), and the U.S. Government Domestic Terrorism Concept of Operations Plan (CONPLAN). In addition, through the implementation of NIMS, NRP embodies an all-hazards perspective that provides the structure and mechanisms for national-level policy and operational direction for domestic incident management. The NRP is intended to be a truly national, comprehensive preparedness and response system that will govern federal response to a wide range of "incidents of national significance" and provide a policy framework for coordination of federal, state, and local governments; nongovernmental organizations; and private sector resources.
Stakeholder Involvement
Both NRP and NIMS have been developed in a top down manner, centrally coordinated by DHS. Views differ on the scope and intent of stakeholder involvement in developing NRP and NIMS, and the authors of this article represent diverging perspectives.
Charlie Hess, DHS, states that the development process included extensive review and participation by a broad range of partners and stakeholders. It involved all of the federal departments and agencies; state, local, and tribal government stakeholders; and the private sector.
While acknowledging this, Jack Harrald, The George Washington University, notes that development of NRP, like all policy development, was not a pretty process. When President Bush signed HSPD-5, DHS faced impossible deadlines driven by a perceived immediate terrorism threat. An Interim NRP was to be issued by April 1, 2003; NIMS by June 1, 2003; and a fully implemented NRP by September 2003. These deadlines proved to be counterproductive, and the initial documents released for review were woefully inadequate. They ignored or eliminated critical elements of the current system, most notably disaster mitigation, FRP emergency support function structure, and the process and structure of the NCP as it pertained to oil and hazardous substance releases.
Harrald notes that the academic hazards community was largely absent and uninvolved during the development of this critical national policy framework. Social scientists have examined organizational responses to large, complex events and know that open, adaptive, organizational systems work best; that emergent organizations always occur; and that the most effective immediate responses are taken by those affected by the disaster. The NRP and NIMS, however, set up a much more formal and structured system for dealing with extreme events. A dangerous sign is the volume of acronyms for organizations (e.g., HSOC, NRCC, JFO, IIMG, JDCC, LEOC) and roles (e.g., PFO, SAC, FOC, FRC, FOSC). The NRP has a six-page listing of acronyms that enables readers to decode these terms and specifies detailed, complex, organizational relationships. The NRP recognizes and specifies that extensive training is necessary for those who will operate within the system. This training represents an implicit system boundary. Among the open questions that could concern the hazards research community are:
- Will a centralized, highly structured, closed system entrusted solely to trained professionals work effectively for managing complex events?
- Will the hazards research community be able to evaluate and assist in the evolution of this system?
- Was such a sweeping change necessary to achieve immediate policy goals?
- What will be the unintended consequences of this policy initiative?
The authors agree that the final product was much improved after state and local review, extensive comment from within the federal government, and a restructuring of the drafting process. However, the resulting patchwork of plans and changes is dauntingly complex. The NRP, for example, will maintain and expand the Emergency Support Function (ESF) structure (to include an economic stabilization, community recovery, and mitigation ESF) and retain NCP as a supporting plan. The FRP, CONPLAN, the Interim NRP, and FRERP will be superseded by the final NRP. The NRP provides additional incident annexes that address cyber, nuclear, biological, and other terrorism incidents. Its structure preserves the separate roles and responsibilities of the U.S. Department of Justice's Federal Bureau of Investigation (FBI) and the Department of Health and Human Services' Centers for Disease Control and Prevention, while defining relationships and coordinating mechanisms.
Next Steps: Challenges and Opportunities
Developing standards and a new approach to incident management presents numerous challenges, such as:
- Creating a New Way of Doing Business While Keeping What Works: Early feedback on NRP stressed the need to preserve and reinforce what works well in the creation of a new approach to incident management. The challenge is to build on the multitude of existing authorities and processes, span the gaps between them, and establish a new, comprehensive system.
- Combining Multiple Approaches into a Single System: Creating a single framework flexible enough to encompass the role of the federal government and adequately support state and local incident managers, while also accounting for situations where the federal government exercises direct incident management authorities and responsibilities (such as the FBI's role in countering terrorists and the federal on-scene coordinator's role under NCP in responding to pollution incidents) will require significant communication and relationship building.
- Shifting the Traditional Focus on Response and Recovery: The majority of existing incident management plans focus on response and recovery. As NRP expands beyond this traditional function to focus on prevention and preparedness, these efforts become major considerations in the domestic terrorism arena. Expanding into areas with limited legislative authority and funding for preincident actions is a challenge.
- Encouraging Federal-to-Federal Support without Legislation: HSPD-5 envisions activating and using NRP to guide interagency mutual aid absent a disaster or emergency declaration. The Stafford Act authorizes the DHS secretary and the emergency preparedness and response undersecretary (FEMA director) to "task" (mission assign) departments and agencies after an emergency or disaster declaration. This tasking authority does not exist for events of national significance that do not result in a presidential declaration. Without the Stafford Act authorities, interagency mutual aid is essentially voluntary in nature. Agencies will need to commit to some type of interagency mutual aid or assistance agreement to execute those interagency activities that do not rise to the level of a presidentially declared disaster.
- Working within Time Constraints: Developing a national plan is a collaborative process. Meeting ambitious timelines without hindering collaboration may be difficult.
These are just a few of the challenges associated with the creation of a comprehensive and user-friendly all-hazards National Response Plan. Other considerations include developing supporting annexes, identifying the correct emergency support structure and mechanisms, synchronizing terminology and organizational element descriptors so that everyone understands the plan, and deciding who pays and under what circumstances. Compliance with NRP will be mandatory for all federal agencies and, in order to remain eligible for federal funding, state governments must modify existing incident management and emergency operations plans within a year of policy implementation. Local governments and nongovernmental and private organizations will also have to adjust plans and procedures to operate within the NRP/NIMS context.
Looking Ahead
Even with the challenges noted above, the new NRP represents a significant step forward in achieving a holistic approach to domestic incident prevention, preparedness, response, and recovery-a plan that will be tested, exercised, used, and fine-tuned to retain and enhance its relevance in this increasingly uncertain world. For it to be truly successful, it is crucial that those outside of government remain actively involved in monitoring the implementation process and helping improve its products.
Charlie Hess
U.S. Department of Homeland Security
Jack Harrald
Institute for Crisis, Disaster, and Risk Management
The George Washington University
USGS Studies Shifting Sands
In the midst of what is predicted to be an above-normal Atlantic hurricane season, word that 61 percent of the Gulf Coast shoreline is eroding does not come as welcome news. This finding is part of a recent assess-ment of shoreline change along the Gulf of Mexico conducted by the U.S. Geological Survey's (USGS) Coastal and Marine Geology Program.
The National Assessment of Shoreline Change Project, which will ultimately include open-ocean sandy shores of the Atlantic and Pacific Coasts and parts of Alaska and Hawaii, was initiated to address the need for accurate shoreline change data, including rates and trends that are consistent among regions. As more and more people move to the coast and erosion becomes a greater threat to lives, coastal property, and critical infrastructure, access to this historical data becomes increasingly valuable to coastal managers in their ongoing efforts to protect communities.
The USGS program is the sole program dedicated to tracking coastal change with standard repeatable methods for mapping and analyzing shoreline move-ment so that periodic updates regarding coastal erosion and land loss can be made nationally in a manner that is systematic and internally consistent. More information about the project, a copy of the initial report National Assessment of Shoreline Change: Part 1, Historical Shoreline Changes and Associated Coastal Land Loss along the U.S. Gulf of Mexico (2004, 44 pp., free), and a data catalog and Internet Map Server that complement the report can be found at http://coastal.er.usgs.gov/shoreline-change/. Information about the USGS Coastal and Marine Geology Program can be found at http://marine.usgs.gov/.