Comments on: How to Improve Homeland Security: Pets, Kids, and a Yellow School Bus http://www.hlswatch.com/2009/10/22/how-to-improve-homeland-security-pets-kids-and-a-yellow-school-bus/ News and analysis of critical issues in homeland security today. Sat, 11 Feb 2012 21:07:03 +0000 hourly 1 http://wordpress.org/?v=3.1 By: William R. Cumming http://www.hlswatch.com/2009/10/22/how-to-improve-homeland-security-pets-kids-and-a-yellow-school-bus/comment-page-1/#comment-136990 William R. Cumming Fri, 23 Oct 2009 16:21:17 +0000 http://www.hlswatch.com/?p=6861#comment-136990 Amazing I thought my take on policy formulation in FEMA in my time on one issue might draw a comment. Who is reading this if no one interested in Children except the POSTERS? Hey the kids are really really important. I always wonder about impact on the kids in the US AOR's in AF-PAK and Iraq or elsewhere? Are we raising a new and even more militant and anti-US generation? Amazing I thought my take on policy formulation in FEMA in my time on one issue might draw a comment. Who is reading this if no one interested in Children except the POSTERS?

Hey the kids are really really important.

I always wonder about impact on the kids in the US AOR’s in AF-PAK and Iraq or elsewhere? Are we raising a new and even more militant and anti-US generation?

]]> By: William R. Cumming http://www.hlswatch.com/2009/10/22/how-to-improve-homeland-security-pets-kids-and-a-yellow-school-bus/comment-page-1/#comment-136981 William R. Cumming Thu, 22 Oct 2009 18:42:45 +0000 http://www.hlswatch.com/?p=6861#comment-136981 I have long argued that the question "Is FEMA the Ultimate Safety Net" should be decided by Congress and the White House. IN 1993 the remarkable report, remarkable because it was so honest, "Coping With Catastrophe" was released following up lessons learned from Hurricane Andrew, Augsut 1992! That report concluded that the President and Congress get the disaster response they want. Based on the evidence since 1950 both those entities want and inefficient funding mechanism that will help hold harmless those who often through their own negilence and lack of mitigation, create disasters from the built environment and their decisions. State and local governments, together with the Federal Government, are leaders in making unwise development decisions leading to waste, fraud, and abuse. Example, almost 65% of HUD Urban Renewal monies went into the nation's flood plains and now of course again those areas and their mayors beg for more federal funding. A prime example, delta area of CA and STATEN ISLAND, N.Y. There are plenty of examples of wise land use decisions being made by private individuals and organizations. Try the Nature Conservancy for one. [Note they have not been free from insider self-dealing!] Another example, the National Parks! But some things are functionally dependent on water resources. So subject to flooding. EPA often funds water and sewer in flood prone areas. They could do better but just don't want to since hard work. By the way what happened to the redraft of EO 11988 issued by President Carter [not much of an improvement] but still could be a step forwards and not backwards. Well we (the US) have had several centuries to despoil a continental land mass. Mostly succeeded in my opinion. What does this have to do with FEMA role? FEMA is largely a grant making agency, an administrative not a regulatory agency, and one so small and underfunded not very competent on technical issues and really does NOT want to know the secondary and tertiary impacts of its decisions. Administrator Fugate I hope was not too shocked by what he has found since arriving in FEMA's top post. Secretary Chertoff told his successor that 50% of his time was spent on FEMA issues. Fascinating given the vast DHS portfolio of programs, functions, and activities. Oh and by the way how are ops going in American Samoa? A long, long, long, long way away from DC! I have long argued that the question “Is FEMA the Ultimate Safety Net” should be decided by Congress and the White House. IN 1993 the remarkable report, remarkable because it was so honest, “Coping With Catastrophe” was released following up lessons learned from Hurricane Andrew, Augsut 1992! That report concluded that the President and Congress get the disaster response they want. Based on the evidence since 1950 both those entities want and inefficient funding mechanism that will help hold harmless those who often through their own negilence and lack of mitigation, create disasters from the built environment and their decisions. State and local governments, together with the Federal Government, are leaders in making unwise development decisions leading to waste, fraud, and abuse. Example, almost 65% of HUD Urban Renewal monies went into the nation’s flood plains and now of course again those areas and their mayors beg for more federal funding. A prime example, delta area of CA and STATEN ISLAND, N.Y. There are plenty of examples of wise land use decisions being made by private individuals and organizations. Try the Nature Conservancy for one. [Note they have not been free from insider self-dealing!] Another example, the National Parks! But some things are functionally dependent on water resources. So subject to flooding. EPA often funds water and sewer in flood prone areas. They could do better but just don’t want to since hard work. By the way what happened to the redraft of EO 11988 issued by President Carter [not much of an improvement] but still could be a step forwards and not backwards. Well we (the US) have had several centuries to despoil a continental land mass. Mostly succeeded in my opinion. What does this have to do with FEMA role? FEMA is largely a grant making agency, an administrative not a regulatory agency, and one so small and underfunded not very competent on technical issues and really does NOT want to know the secondary and tertiary impacts of its decisions. Administrator Fugate I hope was not too shocked by what he has found since arriving in FEMA’s top post. Secretary Chertoff told his successor that 50% of his time was spent on FEMA issues. Fascinating given the vast DHS portfolio of programs, functions, and activities. Oh and by the way how are ops going in American Samoa? A long, long, long, long way away from DC!

]]> By: William R. Cumming http://www.hlswatch.com/2009/10/22/how-to-improve-homeland-security-pets-kids-and-a-yellow-school-bus/comment-page-1/#comment-136979 William R. Cumming Thu, 22 Oct 2009 16:44:37 +0000 http://www.hlswatch.com/?p=6861#comment-136979 Important post and topic by guest poster. Okay here goes! Yes, blame me. First, the Stafford Act contains no specific standards or mandates with respect to preparedness and the closest it comes is Title VI from old Federal Civil Defense Act of 1950, Public Law 81-920. The Disaster Relief Act of 1950, the first permanent disaster legislation was Public Law 81-875. These citations are the modern form and that not adopted until after these statutes became law. Again, FEMA's generic policy for preparedness was to split the entire population into two pieces. The General Public, which included teachers, schools, and Kids, and the second portion the response community named principally First Responders by Deputy Fire Administrator and USFA former General Counsel when incorporated into FEMA in 1979. Before that USFA was in Dept. of Commerce. Okay was that a mistake, well maybe but at the time of the civil defense program which existed from 1951-1994, the STATES were to provide standard for preparedness and response with funding and technical support from the FEDS. Of course that largely failed. So with disaster relief, was it an appropriate policy. I was involved in several efforts to determine whether that policy framework was correct including my time in FEMA 1979-1999. Because the highest standards of preparedness involving FEMA were those created by NRC and FEMA in NUREG 0654 and the REPP activity which was fully subject to administrative litigation, intelligent liscensing intervenors worked to break down the FEMA split between the General Public and responder community. By the way in another comment related to this I cited NUREG-1100 for the WASH report which was incorrect. It was WASH 1100 often referred to as the Rasmussen Report discussing probability and consequences of a core melt nuclear power plant accident. As the lead litigator for FEMA for part of its history when assigned to REP I tried to freeze FEMA policy to make it more defensible unless pushed to the wall to change it. Another example, relocation from the EPZ of 80% of the population was considered to be within FEMA guidance. Obviously a relocation of 80% of the population of NOLA was not and could not be considered a success during Katrina. Now of course FEMA is in the box for all evacutions successes even though NOLA long ago had prevented top-notch evac planning and execution. That is documented. Also of course Katrina caused the largest separation of children under 18 from their parents (the Commission criteria concerning disasters and children) and that figure for NOLA alone is over 200,000 including all of LA. So its great to have children broken out as a group for disaster planning. But hey wait a minute. Part of my arguments for not doing so in the 80's was guess who--parents and schools. For 9 months of the year almost 50 students are housed in k-12 ops of various kinds. These schools have only reluctantly taken on In LOCO Parentis responsibility for emergency preparedness including planning. Often have no training even in first aid. Having listed to role conflict testimony over MONTHS learned that parents often pick up kids in emergencies because they don't trust the schools. Also what about Parents? Well of course the sociology and demography and philosophy of parenting has changed a great deal in last 25 years. Now many more children are latch key or have no adult supervision for most of the day. So again I guess it is good to make FEMA make up for all the societal and educational deficiencies in the US. And by the way speaking of evacuation--guess which federal department is to make sure Congress and the Judiciary can escape a disaster (other than self-help of course) yes that is correct the Department of Justice. See EO 12656 as amended. And as to COOP and COG try relocating a US attorny's office and the federal court houses. It does happen--just check with CEDAR RAPIDS, IA where the court house was built fairly recently on what becomes an Island periodically during flood stage. So if I have ground enough axes will sign off. Just noting for the record that Congress has about 100 other groups not specifically addressed for preparedness standards and mandates in the STAFFORD ACT. So get to work Congress. And if the US Coast Guard develops any more power in DHS and FEMA than FEMA will be largely than DOD and DHS combined because it no longer will be a cooperative or collaborative agency but always will go solo with its contractor support because Congress and the Coast Guard will have adopted the reverse of the principal delegate or die. An empire being build based on policy necessity is still fun to watch. FEMA has already helped bounce ARC from lead on ESF-6 despite not being anywhere close to fulling the requirements of that support function so why not take on worrying about 50 million kids in disaters. Hey the parents of the US and the schools really can do without the responsibility for the kids in their care. Being facetious of course. kids are the future. And glad the little boy in Georgia finally identified. Important post and topic by guest poster. Okay here goes! Yes, blame me. First, the Stafford Act contains no specific standards or mandates with respect to preparedness and the closest it comes is Title VI from old Federal Civil Defense Act of 1950, Public Law 81-920. The Disaster Relief Act of 1950, the first permanent disaster legislation was Public Law 81-875. These citations are the modern form and that not adopted until after these statutes became law.
Again, FEMA’s generic policy for preparedness was to split the entire population into two pieces. The General Public, which included teachers, schools, and Kids, and the second portion the response community named principally First Responders by Deputy Fire Administrator and USFA former General Counsel when incorporated into FEMA in 1979. Before that USFA was in Dept. of Commerce.
Okay was that a mistake, well maybe but at the time of the civil defense program which existed from 1951-1994, the STATES were to provide standard for preparedness and response with funding and technical support from the FEDS. Of course that largely failed. So with disaster relief, was it an appropriate policy. I was involved in several efforts to determine whether that policy framework was correct including my time in FEMA 1979-1999. Because the highest standards of preparedness involving FEMA were those created by NRC and FEMA in NUREG 0654 and the REPP activity which was fully subject to administrative litigation, intelligent liscensing intervenors worked to break down the FEMA split between the General Public and responder community. By the way in another comment related to this I cited NUREG-1100 for the WASH report which was incorrect. It was WASH 1100 often referred to as the Rasmussen Report discussing probability and consequences of a core melt nuclear power plant accident. As the lead litigator for FEMA for part of its history when assigned to REP I tried to freeze FEMA policy to make it more defensible unless pushed to the wall to change it. Another example, relocation from the EPZ of 80% of the population was considered to be within FEMA guidance. Obviously a relocation of 80% of the population of NOLA was not and could not be considered a success during Katrina. Now of course FEMA is in the box for all evacutions successes even though NOLA long ago had prevented top-notch evac planning and execution. That is documented. Also of course Katrina caused the largest separation of children under 18 from their parents (the Commission criteria concerning disasters and children) and that figure for NOLA alone is over 200,000 including all of LA.

So its great to have children broken out as a group for disaster planning. But hey wait a minute. Part of my arguments for not doing so in the 80′s was guess who–parents and schools. For 9 months of the year almost 50 students are housed in k-12 ops of various kinds. These schools have only reluctantly taken on In LOCO Parentis responsibility for emergency preparedness including planning. Often have no training even in first aid. Having listed to role conflict testimony over MONTHS learned that parents often pick up kids in emergencies because they don’t trust the schools. Also what about Parents? Well of course the sociology and demography and philosophy of parenting has changed a great deal in last 25 years. Now many more children are latch key or have no adult supervision for most of the day. So again I guess it is good to make FEMA make up for all the societal and educational deficiencies in the US. And by the way speaking of evacuation–guess which federal department is to make sure Congress and the Judiciary can escape a disaster (other than self-help of course) yes that is correct the Department of Justice. See EO 12656 as amended. And as to COOP and COG try relocating a US attorny’s office and the federal court houses. It does happen–just check with CEDAR RAPIDS, IA where the court house was built fairly recently on what becomes an Island periodically during flood stage.

So if I have ground enough axes will sign off. Just noting for the record that Congress has about 100 other groups not specifically addressed for preparedness standards and mandates in the STAFFORD ACT. So get to work Congress. And if the US Coast Guard develops any more power in DHS and FEMA than FEMA will be largely than DOD and DHS combined because it no longer will be a cooperative or collaborative agency but always will go solo with its contractor support because Congress and the Coast Guard will have adopted the reverse of the principal delegate or die. An empire being build based on policy necessity is still fun to watch. FEMA has already helped bounce ARC from lead on ESF-6 despite not being anywhere close to fulling the requirements of that support function so why not take on worrying about 50 million kids in disaters. Hey the parents of the US and the schools really can do without the responsibility for the kids in their care. Being facetious of course. kids are the future. And glad the little boy in Georgia finally identified.

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