Tuesday, November 23, 2010

The DHS Integrated Planning System-January 2009

In January 2009 DHS released its Integrated Planning System Document. As usual no description of those preparing the document, what internal or external review accomplished, or exactly what official of DHS gave final approval and how it was adopted and issued. Like "Topsy" I guess it just "grew"!

It appears to be largely a formatting document and to give a heirarchy to various other documents issued by DHS and HSC over time and now of course NSC for homeland security. Probably useful for that limited purpose. If it intended to have broader reach would be happy to hear what that intention was and whether someone in DHS thinks it was reached.

My problem is that the document could have achieved real significance if it accomplished one thing that in my experience federal plans of various types never do. That is establish a planning basis for each plan, and tell folks exactly how to derive a planning basis for each plan.

What does this mean really? Well plans are conceived to accomplish certain things, in the context of DHS and FEMA usually they are designed to provide and effective and efficient response to some incident or event. But they never seem to indicate exactly the metrics of the event they intend to plan for when operative. And they rarely give an trigger for the plan that is automatic, or almost automatic. An example is the Federal Radiological Emergency Response Plan involving off-site safey at fixed nuclear power stations. I long advocated unsuccessfully that when NRC went to General Alert status on any plant or the utility declared that status they the FRERP would start rolling. Sometimes this kind of rigidity makes no sense. But it might have helped the federal response in both Hurricane's Andrew (1992) and Katrina (2005)if some appropriate high official had made the announcement that the plan was in effect and being utilized to the extent applicable. Perhaps a declaration made public that the NCP at 40 CFR Part 300 was being used in the BP Catastrophe would have helped all to understand the response process.

Back to the planning basis! I often thought the planning basis should be developed based on the most likely or most probable incident or event. Now I realize that that will probably generate too much heat without much light. So I have now converted to the proposition that the metrics of the capability of the plan should focus on current capabilities of all signatories and participants in the plan. This may also generate heat but hopefully some light also. An example would be for mass casualty events, medical care would be available to provide for 150 mass trauma casualties. If this sounds low it probably is still too high for most jurisdictions. What we do know is that 700 mass trauma victims anywhere in the US even the largest and best served medically could not handle 700 victims.

My point is simple! Start with a planning base that we know the signatories and participants in the plan can handle. Then also design the mobilization system needed to expand resources for larger scale events, including logistics systems, priorities and allocations of resources from outside the impacted area, personnel for 24/7 operations as long as necessary and other factors that make preparedness sense. This planning basis would of course be made public [probably also for comment] so that the jurisdictions real capacity is known and others not in the planning business can plan against it for their own individual protection, family protection, business or non-profit entity protection.

So hoping this concept can be fleshed out and revised in the next edition of this somewhat anonymous document.

One favorite of mine would be to plan for up to 500K homeless and 50K deceased. This would allow a broad enough planning basis if achieved as part of current capabiities to expand to foreseeable events of a much larger scale. This ability to expand operations is what these plans should be all about. And thus a basic flaw in current plans could be fixed.