Are There Too Many Federal Directives and Guidance Documents?

Based on the recent question I posed about what documents readers are/are not interested in, and fueled by several conversations with federal officials and contractors dealing with the aftermath of H. Sandy, I wonder whether the U.S. emergency management system at the federal level has become excessively demanding.  And are the directives and requirements excessive with regard to current state and local capabilities and budgets?

My personal view is that President Policy Directive #8 (PPD8), issued in march 2011, and the various documents and requirement flowing from it, was the tipping point. It seems to me that the directives get more abstract, difficult, and lengthy, yet the the staff and budgets at various agencies, organizations –and particularly state and local government–are sloping downward.  Added to those problems, federal grants are down significantly and many federally-supported educational efforts have been cut.

Even with all domains of society involved in disaster response and recovery, the likelihood of achieving the lofty goals and objectives  of the above-mentioned directives and frameworks with current resources is not promising.

Now, what is your view about this topic?  I am curious if I am alone in climbing out this branch of the tree!

NOTE: Be sure to read the comments. They make the point better than I did.

7 thoughts on “Are There Too Many Federal Directives and Guidance Documents?

  1. Jono left a few off the list.

    Stafford Act (no really a guidance document)
    Protection Framework
    Prevention Framework (forthcoming)
    National Infrastructure Protection Plan (NIPP)
    NIMS
    National Strategic Plan for Public Health Preparedness and Response (CDC)
    Public Health Preparedness Capabilities: National Standards for State and Local Planning (CDC)
    Healthcare Preparedness Capabilities: National Guidance for Healthcare System Preparedness (HHS/ASPR)
    CPG-301: EM Planning Guide for Special Needs Populations
    NIMS Job Credentialing Titles
    NIMS Resource Types
    EMAC and other mutual aid agreements
    HSEEP and EEGs
    Emergency Responder Health Monitoring and Surveillance (ERHMS)
    Guidance on Planning for Integration of Functional Needs Support Services in General Population Shelters (FEMA)
    PETS Act
    And on and on and on………..

    More is better???

  2. At CNA we recently completed a county-wide planning assessment, where we compiled and reviewed 22 relevant emergency management standards and federal regulatory and compliance guidance documents. From that we then developed an assessment tool that identified 535 unique planning requirements recommended for local government. That is a significant amount of requirements for a local county to implement, particulalry when you think of the resources typically available at the local level.

  3. If you read the original PPD, the process is laid out for the documents. Inclusion of everyone is the key but there needs to be other partners. Emergency management has taken many years to manage response and frequently has to also support organization of recovery efforts. New partners must accept leadership of the other components. Critical infrastructure, chambers of commerce, and the insurance industry should all be adopting new roles in support of this national initiative.

    Brenda Pittman
    EMS & CISM Coordinator
    County of Lancaster PA

  4. The most replicable part of the emergency management equation, local emergency management, simply can’t absorb the vast number of guidance and directives stemming from well intentioned doctrinal bodies.

    PPD – 8
    • Response Framework
    • Recovery Framework
    • Mitigation Framework
    • Preparedness Framework
    HSPD – 5
    CPG 101
    THIRA
    National Security Presidential Directive-51/Homeland Security Presidential Directive-20
    National Continuity Policy Implementation Plan
    Federal Continuity Directive (FCD) 1 – (Revised October 2012)
    Federal Continuity Directive (FCD) 2
    Continuity Guidance Circular (CGC) 1
    Continuity Guidance Circular (CGC) 2
    (the list could continue…)

    I strongly believe the frameworks being developed have great potential, however, implementation at the local level must be achievable, which would include adequately resourcing State/Territory/Tribal and local emergency management with the human resources (via grants such as EMPG) necessary for plan development, planning, exercising and training. PPD-8 rollouts have been “check list” oriented and I fear we are too quickly declaring “victory” by simply publishing doctrine/directives without property resourcing the local emergency management community for successful implementation.

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