Saturday, October 16, 2010

Pablum or Steak--OIG/DHS or GAO--And "Substantial Progress"

Well on September 10, 2010 DHS/OIG again analyzed the capability of FEMA to conduct its operations in a catastrophic situation. The report updates an early 2008 report concerning the same subject. Unfortunately, the report fails again to distinguish between actual accomplishments and focuses on whether FEMA has achieved the laughable goal of "substantial progress"! This favorite term of the leadership in FEMA is totally meaningless since it derives from no metrics, no hard analysis, ignores deadlines, and also fails to determine whether the program, function, or activity mission or goal will be achieved anytime soon. I was actually in the room when the term was invented and employed for the first time with a brilliant but quirky civil servant, now a female SES in FEMA close to retirement came up with the terminology in the context of the REP [Radiological Preparedness Program] and NRC at the Commissioner level was pushing for a FEMA statement so they could liscense a particular nuclear power plant.

The bottom line is that always be watchful when any component of FEMA, in particular when trying to provide reporting data to Congress or other oversight organizations employs the term "substantial progress"! If the Pyramid Builders in Egypt had used that term as the measuring stick those magnificant structures would remain unbuilt in the desert.

That stated, OIG/DHS is struggling to figure out again and again how and why FEMA gets away with constantly missing statutory mandates. The interesting thing is that the reports often list the mandate but instead of labeling the failure point out that some new report or effort is yet to arrive and implicit in the OIG/DHS finding is this makes okay the missing of the deadline. For example, now the excuse is rewriting of HSPD's or other guidance emanating from this WH. Much of the first two years of the Administration was disappearance of important doctrinal statements, even draft Executive Orders, never to reappear or at least not yet. Leading example, the revision of E.O. 11988 conerning flood plain management.

In the DHS/OIG report other efforts are mentioned but the OIG report fails to mention either the predecessor documents still in place or why those failed. Example, the National Mitigation Strategy of 1995 and the Pre-Disaster Mitigation Strategy of 1998 are not mentioned even while FEMA struggles to implement a new statutory mandate for a National Mitigation Strategy. Just further documentation that FEMA has no historical or management memory and is likely to never in its history become what the Public Administration types call a "Learning Organization". It just again proves that FEMA is terrible about the details of governance and shows how weak the support staff offices are like procurement, Chief Counsel, policy shop etc. Yet no one seems to understand why FEMA repeated fails to get "it" with "it" being basic bureacratic governance. We used to laugh at exercise deficiencies. Were they the result of a bad plan? Were they the result of poor training or implementation? Were they just exercise anomalies? Well sometimes we concluded that the FEMA personnel just were not capable of being trained.

GAO has produced two interesting pieces on FEMA preparedness, largely in the context of PKEMA 2006. In 2008 and 2009 reports and testimony indicated FEMA making "substantial progress" but at least what the progress consisted of. Like the DHS/OIG however the GAO also ducked reaching the conclusion of "NO Effective Preparedness" by examining development, implementation, or operational capabilty so the US is left with the feel good sense that yes passage of time equals some improvement when the National Emergency System envisage as long ago as the language of Public Law 920 of the 81st Congress still does not exist.

Well I guess one can always hope for improvement. And did I mention that again DHS/OIG relies on compliance with a very weak reed, CPG-101 as far as state capability when the states are again allowed to assess themselves.

By the way the best self-assessment of STATE preparedness I have seen in the last few years is Governor Rendell's study group of why an ice storm brought Pennsyvlania to a complete stop several years ago. It should be a model study for other governors. And what exactly were the self-assessments of the GOM states impacted by Katrina. Mostly nothing and more pablum than steak.