Thursday, November 18, 2010

The National Response Framework--Plan Consolidation

Let's go back for a moment. The Homeland Security Strategy of 2002 (July 6, 2002); the Homeland Security Act of 2002 (November 23, 2002); the Homeland Security Reorganization Plan at page 15 (November 25, 2002); HSPD-5 (February 28,2003); all called for consolidation of FEDERAL RESPONSE PLANS and in particular the Federal Response Plan, the Federal Radiological Emergency Response Plan, the National Contingency Plan for Oil Spills and Hazardous Materials Releases, and the CONOPLAN TERRORISM were all targeted for inclusion. Of course there are other federal response plans but for the moment let's ignore those plans. None of the above mentioned technically cover response to incidents and events on federally owned property or facilities which theoretically are the responsibility of the federal owner. But as we saw on 9/11/01 Arlington County VA did more in actual response than did the entirety of the DOD with respect to the terrorist strike on the Pentagon.
Okay so now since January 2008 we have the NRF [National Response Framework]! At some point it would be an important piece of US history to delve into the evolution of the mandate, from its inception until its failure.

So this will be a short and dirty history and probably contains some errors. What I would point out is the PLAN RECONCILIATION DOC posted on the homepage of this blog as giving some indication of the difficulty of the quest for this "holy grail"!

The inital FEDERAL RESPONSE PLAN was published and I would argue formally adopted in May 1992. Unfortunately, Hurrican Andrew made landfall [twice] in the US in August. So training and implementation was not yet in effect and in fact the first Bush Administration could not decide whether the plan had acutally been implemented or not for Hurricane Andrew response. That plan was partially revised and updated in 1999.
Then of course the CONOPLAN for Domestic Terrorism was published in January 2001. This represented a long struggle to bring the DOJ/FBI TEAM? back to the table after the refusal of DOJ to formally be involved in the Federal RESPONSE Plan. I argue that CONOPLAN is still in effect and until someone shows me a formal supersession document and incorporation into some other formal document will continue to persist in that belief.

Then 9/11/01 and official reaction to that event. A so-called National Response Plan was oddly assigned not to the Emergency Preparedness and Response Directorate of DHS when its doors opened in March but to Admiral Loy's Directorate which I believe was Border and Customs Enforcement or some variation thereof. Now Admiral Loy has a sterling reputation but despite his rising to Deputy Secretary of DHS and other honors, he blew it with the assignment of the NRP. He contracted with RAND for production and the output was a document that EM types and other First Responders at the STATE and their local level just could not figure out and complained they had been left out.

By the late fall of 2004 a draft document was circulating and pretty much announced as in effect by early December 2004. Unfortunately, as the OIG/DHS has concluded it was not formally signed off final and issued until April 12, 2005. And then guess what? Hurricane Katrina!

So once again the effort was tested before it could really be implemented. Portions did not work with the result that Secretary Chertoff, and Chief Paulison, Acting head of the FEDERAL EMERGENCY MANAGEMENT OFFICE [not Agency] worked to reconcile problems resulting in the issuance of the NRF [National Response Framework] in January 2008. Close review of that document demonstrates that it is a design concept and I would argue that no one in DHS really understands whether its various developmental tasks have been accomplished or not. For example, the original 15 National Preparedness Goals, now largely shrunk to 8 [and none involving regulated entities] are each receiving detailed work to develop SOP and CONOPLANs that will be the gold standard.
It appears that the OBAMA Administration may well have left office without producing any document that summarizes the total endproduct of the NRF and its design for response.

In the meantime we now have Admiral Thad Allen another Coastie with a sterling reputation innocently admitting that he did not understand how the totality of the federal response system worked. He has stated in an interview he did not understand how or why DOD was not involved early in the BP Catastrophe. He has stated he did not understand how or why the STATE and their local governments were confused over the response. He also has revealed that certain aspects of the National Contingency Plan, including funding arrangements, had been identified as problematic but funding to fix that plan and its implementation had not occurred as far back as 1997 under the Clinton Administration.

So here is my challenge to the 112th Congress! Hold hearings and have key witnesses describe to US the entirety of the federal response planning system and how it works and how it is funded and who will be showing up at federal, state or local level, or the for-profit sector, or the non-profit sector or whatever! Because the opaqueness of the current implementation of the NRF is a clear and present danger, if not to the national security [I would argue it is] but at least to domestic tranquillity.