On May 24, Congressman Bennie Thompson of Mississippi introduced the Emergency Management Support Act (H.R. 3626). I've attached the legislative language as a PDF, and here is a link to a summary of the bill. The bill would direct States, through the Emergency Management Performance Grant, to require local emergency management directors to complete emergency management training within one year after the enactment of the bill; require local emergency management directors to complete recurrent training with certifications to be submitted to FEMA annually; and require FEMA to report to Congress on compliance with this Act.
The Government Affairs Committee had a spirited discussion with Congressman Thompson's staff at the June 6 GAC meeting.
What are your thoughts about the bill?
I think the intent of this legislation is noble, but there are several very significant issues that IAEM should bring up with the sponsors:
1. Emergency management is not incident management. The current language states:
"A State shall require local emergency management directors to successfully complete Federal Emergency Management Agency provided baseline emergency management training developed in accordance with the National Incident Management System." (emphasis added)
Collectively, as an association, IAEM should be messaging in all directions that "emergency management is not the same thing as 'incident management'."
NIMS is focused on response and recovery, exclusively. Emergency managers also manage preparedness and mitigation programs. That is not to say that emergency management does not also obviously play a key role in response and recovery. Rather, it is an acknowledgement that we need to do a lot of education around "what emergency management IS."
This is especially a problem within FEMA itself, as the agency continues to emphasize national-level incident management response and recovery programs and activities, with mitigation/resilience riding shotgun, to the detriment of preparedness activities on a wholescale basis.
Fundamentally, training and readiness of emergency managers (and all other local stakeholders) is a preparedness function. It does not fall within the scope of NIMS-at all.
If the legislative intent, here, is to ensure that states are prioritizing the development of emergency management skills and capabilities at the local level, then better language would be something like this:
"A State shall require local emergency management directors to successfully complete Federal Emergency Management Agency provided comprehensive emergency management training that addresses all aspects of emergency management, to include the various emergency management preparedness, mitigation, response, and recovery programs for state and local assistance that are administered by agencies other than FEMA."
The bottom line is, if we are going to require training for emergency managers as a condition of receiving federal assistance (which is a great idea, in my opinion), we should (A) recognize that emergency management is about more than just disaster response and recovery aka NIMS, and (B) recognize that – in order to be successful in any phase of EM (preparedness, mitigation, response, or recovery) – emergency managers at the local level absolutely need federally-supported and federally-funded training and orientation to the large number of programs and activities across the entire interagency environment.
In order to successfully mitigate, prepare for, respond to, and recover from disasters, emergency managers need training on programs from agencies including EPA, DOT, DOD, HHS, EPA, HUD, SBA, USDA, and FEMA. Not just FEMA and not just NIMS.
2. Consider requiring a minimum set-aside for EMPG awards to be utilized for training emergency managers. Currently, there is no requirement in the EMPG program to devote any portion of the funding to training and professional development of emergency managers. Consequently, some states have great training programs while other states leave a lot to be desired. This is not a criticism, but rather an acknowledgement that there aren't enough resources to go around.
Rather than requiring training "or else no access to recovery funding," perhaps an alternative approach would be to incentivize training on the front end by requiring a portion of EMPG funds already being awarded to be set toward the development and operation of comprehensive training programs at the state and local level.
3. Who is the intended audience? The vast majority of disaster recovery dollars do not flow directly to emergency managers. Rather, they flow to state agencies, counties, municipalities, and other eligible subapplicants.
Currently, there is ZERO required training for any of these subapplicants prior to applying for a FEMA disaster assistance grant such as BRIC or PA.
Even after a jurisdiction applies for and receives a grant, the only training required is limited to administrative controls and oversight of the grant funds themselves.
We do not have a comprehensive system in any way, shape, form, or fashion to bring all of these different entities to the table before a disaster and require them to participate in collaborative dialogue and planning with their emergency managers.
I think this is a really key point…
If we can influence this legislation to require and/or incentivize (such as with an additional 1-5% federal cost share, like what was done with the debris planning pilot a few years ago) all eligible subapplicants to (A) come to the table and meet with their state and local emergency managers and (B) complete some minimum level of training/orientation and or pre-disaster planning, then we will be able to provide a massive tool to help emergency managers engage their communities.
Today, emergency managers have to work through all different kinds of relationships to incentivize the participation of these key stakeholders. If we could tie their receipt of disaster assistance funding to actively participating in their community EM programs, that would solve a ton of our problems overall.
4. Consider incentives for education, certification, and professional standards. I think there is utility to exploring the idea of providing additional and/or incentive funding for jurisdictions that hire educated emergency managers, who employ certified emergency managers, and who pursue standards-based accreditation such as EMAP. No reference in the bill is provided to the "professionalization" of emergency management, other than essentially mandating a training program. When we think about where we need to be moving the discipline and profession of emergency management as a whole, I think we should be working to include reference to things like professional standards in legislation like this.
This is excellent feedback, Jonathan. I will share this with Congressman Thompson's staff.
Excellent, excellent commentary!!
Emergency Services Manager
San Mateo Consolidated Fire Department 1040 E. Hillsdale Boulevard, Foster City, CA 94404
( 650-522-7900 (office)
( 650-226-6854 (mobile)
Jonathan, you make some great points and I whole heartedly agree with your points. I also wanted to point out the mathematics of training requirements. The Bureau of Labor Statistics (2022) reports 11,290 Emergency Managers. At an average of 24 students per class, you would need 470 classes. Let's say just a single class was 24 hours and $5,000 per 8-hour session, this would cost approximately $7,350,000 for a 3-day training class offered 470 times. And to deliver these independently, you would need 940 instructors if they only offered the class once each and you had 2 instructors per class. At 24 students per instructor class, you’d still need another 39 classes.
We are not building the infrastructure of trainers and curriculum to even begin to start offering this solution and online training will not solve this. I started my career teaching CPR classes with 10 students per class. The first time I was able to say I trained 100 students is the first time I became an instructor trainer and trained 10 new instructors who went out and trained 10 students each.
I believe training is necessary, and as you pointed out, probably should be acknowledged and financed legislatively, but we need the training infrastructure to allow this to happen. To build this requirement in a vacuum without the training infrastructure will be an absolute failure and detrimental to our profession.
------------------------------Mary Jo Flynn-NevinsChief of Emergency ServicesSacramento County OESMcClellan CA(916) 874-4671------------------------------
------------------------------Jonathan W. Gaddy256email@example.comOriginal Message:Sent: 06-08-2023 12:13From: Thad HuguleySubject: Emergency Management Support Act - Request for Feedback
------------------------------Thad HuguleyGovernment Affairs DirectorIAEMFalls Church VA(615) 870-9316------------------------------
That's a good analysis, Mary Jo. And, it highlights what I was trying to point to, which is identifying "What is the underlying strategic challenge we are trying to solve?"
I think the issue we need to be focused on is how to incentivize participation of stakeholders at the community level in their emergency management systems. Training is certainly a potential component of that (such as providing an IS course or a faciliated virtual workshop on a regular basis), but it is certainly not the only component.
With that said, a related question would be, "What can we do to ensure all the stakeholder agencies and organizations at the local level are as motivated as possible to participate in their community emergency management systems and encourage them to develop strong, collaborative relationships with their emergency managers?"
Today, we aren't actually doing anything on that front. Other than talking about it.
I think we need to put our money where our mouth is. If we are going to award multi-million dollar mitigation and recovery grants to local government agencies, then I think it is reasonable there should be an expectation that they are (a) involved with and (b) supportive of their emergency management systems, agencies, and staff at a community level. It's simply not required today, and I think that needs to change -- at least on an incentivized basis, with the understanding that we can't ever make participation in the EM program a requirement of receiving federal assistance.
The way things are today, emergency managers are expected to make bricks without straw, and to go out into their communities and build all of these relationships based on good will and relationships alone.
I think tying some incentives to funding for all of the potential subapplicants would make the emergency managers' jobs easier.
We know a few things:
1. A lot of communities have limited capacity and capability to access mitigation funding (FMA, BRIC, etc.).2. A lot of communities need help building stronger emergency management systems.3. Positive outcomes from natural hazards and disasters are correlated with stronger emergency management systems.
My position is that we need to focus on finding ways to bring community partners to the table with their emergency managers to have conversations and identify (and pursue) solutions.
The old paradigm of the emergency manager doing everything "on behalf of" the community is shifting. The new paradigm is collaborative and participatory. Requiring additional training for emergency managers without also providing some kind of requirement for potential subgrantees to come to the table seems duplicative to me.
And, to be honest, I don't think "training" is the challenge in general. I think the underlying challenge we are talking about is how to build stronger community-level emergency management and resilience systems and capabilities.
If we are going to award FEMA dollars to cities, towns, counties, school districts, utilities, etc., AND we are also going to expect the community emergency managers to have their hands wrapped around things in a disaster, then we should also be requiring those sub applicants to come to the table and participate in their communities' emergency management programs.
The way it is today, a sub applicant (like a municipality) can have "no contact" with their emergency manager, and still apply for and receive as many FEMA grants as they want to pursue.
That is very discordant with the overall strategy of building and incentivizing stronger systems at the community level.
In my opinion, emergency managers are only as strong as their relationships.
The advantage of building out some kind of a "participation requirement" tied to grant funding for all these other agencies is that it would incentivize their involvement with emergency management while also providing them a direct way to see that they have a stake in what happens.
A city, county, or other local government should not (in my opinion) be able to just "opt out" of participating with their emergency managers, and yet still also be able to receive unlimited FEMA dollars. But that is the way it is today.
Likewise, we should not expect to be able to solve any problems by continuing to pile on additional requirements for local emergency managers who are already strapped for resources and time. The emergency managers are not the problem, so to speak, and we should stop asking them to "do it for everybody else."
Emergency management is a crucial function of government at all levels, and it cannot be "delegated" to a professional, full-time emergency manager who is then expected to bear responsibility for everything without the participation and vested support of all the other stakeholder agencies and components of the larger system.
------------------------------Jonathan W. Gaddy256firstname.lastname@example.org------------------------------
Jonathan, you make some great points and I whole heartedly agree with your points. I also wanted to point out the mathematics of training requirements. The Bureau of Labor Statistics (2022) reports 11,290 Emergency Managers. At an average of 24 students per class, you would need 470 classes. Let's say just a single class was 24 hours and $5,000 per 8-hour session, this would cost approximately $7,350,000 for a 3-day training class offered 470 times. And to deliver these independently, you would need 940 instructors if they only offered the class once each and you had 2 instructors per class. At 24 students per instructor class, you'd still need another 39 classes.
------------------------------Mary Jo Flynn-NevinsChief of Emergency ServicesSacramento County OESMcClellan CA(916) 874-4671Original Message:Sent: 06-08-2023 15:56From: Jonathan GaddySubject: Emergency Management Support Act - Request for Feedback
Well said, sir! I wholeheartedly agree with your analysis. Now, let's take this to the next step and how can we chip away at this conversation and get it implemented the right way.
------------------------------Jonathan W. Gaddy256email@example.comOriginal Message:Sent: 06-12-2023 09:23From: Mary Jo Flynn-NevinsSubject: Emergency Management Support Act - Request for Feedback
201 Park Washington Ct.Falls Church, VA 22046-4527
Phone+1 703 538 1795
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