The New National Response Plan: Homeland Security Takes an Initial Step

by Scott Regen

At first glance, the Department of Homeland Security's new Interim National Response Plan (INRP) is not an impressive document. It is only 14 pages long, including a title page, transmittal letter and two annexes. If it weren't for the dense bureaucratese, it would be easy to mistake it for a college paper instead of the product of eight months of hard work.

That would be a mistake, because INRP lays the groundwork for revolutionary changes in the federal response to terrorism, major disasters and other emergencies. It is the first document that shows how the Department of Homeland Security (DHS) plans to develop a single, comprehensive approach to domestic incident management. The completed National Response Plan will ultimately:

• Integrate all federal domestic prevention, preparedness, response and recovery plans into a single all-discipline, all-hazards plan.
• Implement a National Incident Management System (NIMS) to ensure federal, state and local governments can work together during a disaster.
• Treat crisis management and consequence management as a single, integrated function that covers the entire life cycle of an event.
• Improve cooperation among federal, state, local, private sector and nongovernmental (NGO) organizations.
• Give a single agency, the Department of Homeland Security (DHS), the lead role in crisis management.

INRP is just what its name implies – an initial document. It was issued (several months late) after eight months of back-and-forth with other federal agencies, states, cities and first responder organizations. It focuses on harmonizing existing federal emergency response plans and incident management leadership responsibilities with the new role played by DHS.

Plan Gaps

The next steps involve development of the National Incident Management System (NIMS) and a final version of the National Response Plan. The latter, an all-hazards plan, will supersede existing federal response plans. These include:

Federal Response Plan (FRP). Developed by the Federal Emergency Management Agency (FEMA), FRP describes how the 27 signatory agencies will deliver resources and aid following major disasters. It is the federal response plan that first responders are most likely to have had contact with.

Federal Radiological Emergency Response Plan (FERP). Another FEMA plan, this one to coordinate the federal response to peacetime radiological emergencies.

U.S. Government Interagency Domestic Terrorism Concept of Operations Plan (CONPLAN). CONPLAN describes the federal response to potential or actual terrorist incidents or threats, particularly those involving weapons of mass destruction (WMD). It is owned by the Federal Bureau of Investigation (FBI).

National Oil and Hazardous Pollution Contingency Plan (NCP). Many responders are familiar with the Environmental Protection Agency's (EPA's) framework for responding to releases of oil, hazardous materials, pollutants and contaminants.

Mass Migration Response Plans. A number of plans detail how to cope with a mass migration of aliens to the United States. The U.S. Immigration and Naturalization Service and State of Florida signed the first such agreement in 1998.

It is easy to see how proliferation of so many plans could cause problems. In fact, a July 2003 report by the National Response Team (NRT), the 16 federal agencies charged with oil and hazardous materials response under NCP, spelled it out. The report highlighted several glaring gaps in existing plans.

The most obvious problem is that each plan is unique. Each one calls for different responses from local agencies. It may make distinct demands in terms of training and equipment, and use unique logistics and funding systems. It may be linked to state and local response plans, but others may not. As a result, large incidents that trigger multiple plans pull responders in too many directions at once. NRT points to the response to the 9/11 attack on the Pentagon as an example.

No individual response plan has provisions for a single federal lead when more than one plan applies. The report notes "identifying the lead for such incidents is particularly complex." It cites a radiological incident that invokes FERP and NCP. The lead agency could be FEMA, FBI or any one of five other agencies.

Nor is the role of the lead federal agency always clear. CONPLAN, for example, designates FBI and FEMA as leads in consultation with Department of Justice. FBI is lead agency for crisis management. Yet the report found that other federal agencies involved in the plan do not know whether FBI will coordinate all federal activities or focus primarily on law enforcement and conflict resolution among agencies.

Order in the House

Remember, this is only the federal tip of the iceberg. While many state and local responders have regional mutual aid agreements that define their roles, large-scale incidents attract organizations that are not covered by those agreements. The combination of multiple federal lead agencies and potentially freelancing responders is a sure recipe for chaos.

The INRP takes the first steps to put this house in order by creating a single structure for the federal government to manage a national emergency. While existing federal plans will remain in effect until the final draft of the National Response Plan, the initial document imposes a level of management and control over them.

If that were all it did, it would be easy to criticize it as simply adding another layer of bureaucracy. The plan's ultimate goal is to harmonize and standardize as many operating procedures as possible so that everyone – from large federal and state agencies to the county sheriff and local volunteer firefighters – uses the same incident command structure, speaks the same terminology and works with interoperable equipment.

Structure

INRP takes effect when: (1) a federal agency requests assistance; (2) state or local groups request aid; (3) two or more federal agencies are "substantially involved in response; and (4) the president directs DHS to assume incident management responsibility. It establishes four specific structures that will enable DHS to manage emergencies.

National Homeland Security Operations Center (HSSOC). The first is the National Homeland Security Operations Center (HSSOC). Located at DHS headquarters, HSOC is DHS's 24/7 nerve center. It is the primary national-level hub for monitoring threats and managing operational communications. Real-time links will connect it to federal agencies, including those that monitor terrorism, as well as state, regional and local centers.

HSOC will call on staff from other agencies to support its monitoring and incident management activities. While it will act as DHS's eyes and ears, other federal agencies still have the right to establish their own emergency operations centers to monitor information from the incident site.

Interagency Incident Management Group. The second modification is establishment of the Interagency Incident Management Group (IIMG). Comprised of senior representatives from DHS, federal agencies and NGOs, it is the headquarters-level group that will coordinate operational management for a specific incident. It gathers and assesses information, sets priorities and helps move resources to the scene.

IIMG replaces the existing DHS Crisis Assessment Team. Under the interim plan, it will coexist with such similar groups as FEMA's Emergency Support Team (EST). INRP says the final NRP will revise the role of those teams, "if any."

Principal Federal Official. The Principal Federal Official (PFO) acts as the DHS secretary's personal representative at the incident scene. The PFO oversees and coordinates federal incident activities. Equally important, he or she is the primary (though not exclusive) federal contact with local authorities to ensure timely federal assistance.

Under the interim document, the PFO will coordinate these actions with other federal officials identified in existing plans. Other federal agencies are required to provide "full and prompt cooperation, resources, and support" for the PFO.

Joint Field Office. INRP calls for a Joint Field Office (JFO) that will house the operations of federal organizations operating at the local level. Where feasible, it will incorporate such existing entities as the Joint Operations Center, Disaster Field Office and other federal offices and teams on the scene. By installing all federal operations in one location, DHS hopes to improve coordination between federal, state and local authorities.

Assistant to the President for Homeland Security. The assistant to the president for Homeland Security is part of the White House staff, not part of DHS. He or she will coordinate interagency incident management policies if terrorists or another nation caused the event.

Moving Forward

INRP takes the first steps towards harmonizing existing federal response plans and lays out the roles and structures DHS will use to manage incidents. DHS plans to publish detailed operating procedures for HSOC, IIMG, PFO and JFO within 60 days.

Under INRP, DHS still relies on existing plans and protocols. Meanwhile, other federal agencies must cooperate with and support DHS. They must also designate representatives to the HSCO and IIMG and modify existing plans within 60 days to comply with INRP.

Development of a National Incident Management System (NIMS) is underway. NIMS will national response plan a unified, national incident command system designed for multiagency coordination and manage resources from pre-event planning through post-event recovery. It will develop common ways to manage communications, intelligence and information, and ensure preparedness by certifying responders for certain tasks.

The final NRP will be an all-hazards, all-disciplines plan that encompasses the entire incident life cycle using NIMS for its standard operating procedures. It will identify what is expected at all levels of government to improve integration, interoperability and compatibility, as well as how information will flow vertically (local- federal) and horizontally (across all agencies in involved in the response). It will also give the federal government the ability to respond proactively.

There are still plenty of issues to resolve. How do we integrate the all-hazards approach with highly specific existing plans? How do we formally bridge from crisis to consequence management? Under what conditions will DHS move proactively? What kind of links should exist between NRP and the private sector? How will NRP implement education and training requirements?

These are all significant issues. The Interim National Response Plan (INRP) is only the first step.

Sidebar: National Response Plan Resources

Initial National Response Plan: A complete copy of the U.S. Department of Homeland Security plan and transmittal letter. www.dhs.gov/interweb/assetlibrary/Initial_NRP_100903.pdf.

Interim Final Reconciliation Analysis of the Federal Response Plan, National Oil and Hazardous Substances Pollution Contingency Plan, U.S. Government Interagency Domestic Terrorism Concept of Operations Plan and the Federal Radiological Emergency Response Plan: The name says it all. Detailed analysis of gaps and overlaps. www.nrt.org/production/nrt/home.nsf/resources/Publications1/$File/Interim_Final_NRT_Plan_Reconciliation_Analysis_Report.pdf.

HSPD-5 Implementation Plan: Overview Briefing, Sept. 25, 2003: In this PowerPoint file, DHS Special Assistant Robert Stephan puts the Initial National Response Plan into perspective. Delivered at George Washington University's Institute for Crisis, Disaster and Risk Management. www.gwu.edu/~icdrm/Stephan-DHS.ppt.