Why is NIMS and ICS the one-size-fits-all response to significant national incidents?
The homeland security enterprise adopted the National Incident Management System (NIMS) with limited scientific, policy or public analysis.
The way I heard the NIMS creation story, several members of the U.S. Forest Service — the home agency of the planet’s preeminent incident command system (ICS) experts – helped bring organization to New York City’s initially chaotic response to the September 11, 2001 attack. The success of their effort led directly to the federal government in 2003 mandating NIMS — with ICS at its core.
In the early “ready, fire, aim” days of homeland security, finding any needle in a haystack was better than wasting time looking for the sharpest needle.
Federal agencies are supposed to use NIMS because a former president — in HSPD 5 — said so. States and local communities are supposed to use NIMS because otherwise they do not get homeland security money. Many emergency management, fire and other public safety professionals believe NIMS should be used because their experience says it works, and there just aren’t any better alternatives.
I am aware of only one academic study — in a 2006 issue of the Journal of Homeland Security and Emergency Management — that questions the utility of ICS and NIMS for major incident response. The paper is “A Critical Evaluation of the Incident Command System and NIMS,” by Dick A. Buck, Joseph E. Trainor, and Benigno E. Aguirre; all from the University of Delaware. The authors support the usefulness of ICS for a variety of incidents, but they conclude usefulness depends on context:
Our findings indicate that ICS is a partial solution to the question of how to organize the societal response in the aftermath of disasters; the system is more or less effective depending on specific characteristics of the incident and the organizations in which it is used. It works best when those utilizing it are part of a community, when the demands being responded to are routine to them, and when social and cultural emergence is at a minimum. ICS does not create a universally applicable bureaucratic organization among responders but rather is a mechanism for inter-organizational coordination designed to impose order on certain dimensions of the chaotic organizational environments of disasters…. Our final conclusions suggest that the present-day efforts in the National Incident Management System (NIMS) to use ICS as a comprehensive principle of disaster management probably will not succeed as intended. [my emphasis]
The relevant finding for me: ICS works best when the incident is “normal” (i.e., a routine disaster — if one can use that term) and the responders know and have worked with each other. That’s what makes me question ICS’ appropriateness as an organizational model for “unique catastrophic incidents” where responders and agencies are strangers to each other.
(I recently read a master’s degree thesis that raises similar questions about the adequacy of ICS for a Mumbai-style incident. I will write more about that study when the author approves.)
The Deepwater Horizon disaster provides a tragic opportunity to examine the uses and limits of ICS and NIMS, including the added bonus of exploring the role the private sector plays in response. Surely that malignantly evolving catastrophe will provide homeland security lessons-to-be learned at least through the next decade. But for now, we have anecdotes from the ground.
What follows is an exchange last week between two people who have knowledgeable perspectives about NIMS, ICS, unified command, and the private sector.
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Person One
Having spent three weeks in [Louisiana] working with the Coast Guard [and] National Guard …, I have some observations and opinions.
I had an opportunity to speak personally with some of the best and brightest from the USCG, BP, EPA, NOAA and others. Although I believe that BP should be more transparent with their information, they have an understandable concern. They feared the release of raw data, including imagery, could be distorted by the media and/or misunderstood.
Take for example the undersea picture of the spewing oil. Although BP has a motive to minimize the amount of the release, there is similar motive by others to maximize the estimated release. I heard one expert on the news talking about an accepted methodology of breaking down the images into small enough bits that the actual volume of the individual bit could be calculated. Once this is done, it is merely necessary to freeze a frame and count the bits. Simple math then gives you an estimated volume from a “bits vs. time” formula. The complication comes in when you try to estimate the volume of a liquid that contains gas (i.e. methane). Once this plume reaches the surface, the methane dissipates into the air. I do not suggest that it is a great idea to dump a bunch of methane into the atmosphere. It does however distort the volume of liquid contaminates that enter the water.
Although booms capture a lot of surface contaminate, my amateur opinion is that the heavy, subsurface tar will have a more devastating, and longer lasting impact on the environment. As the material reaches the surface, volatiles such as benzine and gasoline evaporate and become airborne. What is left is heavier than water, and settles below the surface as a heavy, tar like substance. This heavy tar travels on subsurface currents, such as the loop current, and can surface some distance away from the source, and some time after its birth into the ocean.
I do not believe that the Federal Government has such a brain trust at it disposal that it could immediately make great strides past the feeble BP effort. The feds do not have a reputation of being the best and most efficient at solving problems.
I compliment the USCG. They are an outstanding agency with many capable leaders, and they have experience dealing with oil spills, albeit not of this magnitude. I will not criticize them, and I may suggest an alternative.
My experience with emergency managers, FEMA and NIMS leads me to believe that these people and systems are good at inclusiveness, building teams from people with diverse interests and backgrounds. [But] I have seen this “management by committee” approach cripple response flexibility and efficiency. I would keep BP involved as an expert resource ( I am sure they have more oil well experts than the US Government), and I would involve their leaders in discussions at the higher levels. I would not however make them partners in a Unified Command. I would not give them a voice on resource expenditures. Their interests are potentially different from that of the Government. I would have a strategic plan that reflects the [national incident] commander’s vision…. I would have an integrated intelligence section that can make informed projections so that leaders can make choices and develop strategy based on the best information available. I would put someone in charge who has the necessary experience at leading this size and diversity of effort.
As a citizen watching the destruction of the environment, I would like to see strong leadership, clear vision, a supportable plan, and swiftexecution.
Can we agree on that?
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Person Two
While agreeing with [my colleague’s] fundamental desire for timely and effective operations, I have to disagree with [his] characterization of the concept of NIMS as part of the problem. This is a favorite subject of mine so pardon the diversion from the spill particulars.
I have learned from my [professional colleagues] that some officials, particularly fed and most DoD, view NIMS and its component ICS as unstructured or somehow characterized by consensus decision making. In my experience nothing is further from the truth. ICS and NIMS embrace several familiar concepts as fundamental: unity of effort, consolidated action planning, chain of command, unity of command, span of control.
Put simply: one boss, one set of goals, one plan. ICS essentially got those principles from the military.
My DoD [colleagues] have acknowledged that [operations in the United States] are more complicated than overseas operations in some ways. Given our pluralistic governance, ICS allows for unified command (UC); emergencies don’t respect geographic or regulatory jurisdiction. UC has particular requirements. Members of a UC must have jurisdiction, funding to contribute and authority to speak and decide for their agency. Failing one of those, you’re [just] an agency representative.
UC is a course of study to itself and the product of UC is ONE set of goals (one vision if you will) carried out by one operations section and one organization. The US Forest Service does this admirably, as does the Coast Guard. The rest of the federal agencies, it seems, will take time.
ICS was started by a few metro cities, counties, and state and federal agencies before being chartered by Congress in the 70’s. When ICS was adopted in California by the rest of the local governments in the early 80’s there was a similar sense of disbelief in its utility, [and a] resistance to change — which still exists in some locations — and some incidents [where ICS was applied incorrectly].
A few fires I witnessed enjoyed fully developed overhead staffs, and no one putting the fire out. Many people wanted to argue tactics and dogma; ICS is a command, communication, management and control tool.
The President just visited [my jurisdiction] and NIMS was nowhere to be seen in the action planning. It has taken 30 years to achieve pretty consistent and competent use of ICS in California; I expect the national experience will be similar.
I have seen ICS work in fires, floods, vaccination clinics, special events, earthquakes, chicken flu, and Y2K. A similar but much smaller incident than the Deepwater one was the Cantara Incident of 1991. A train carrying pesticide derailed over the American River dumping a deleterious material into the river, which flowed into a number of recreational lakes downstream through two counties. Fifty-seven involved agencies (fed, state, local and NGO) are listed on the cover sheet of the Incident Action Plan (IAP). Three made up UC. The IAP had six clear incident objectives.
Deepwater response can be organized under NIMS and be effective. [My colleague’s] last paragraph’s desires fit well. In the local hazmat response world, [private sector] get first shot at clean-up. If the [private sector] can’t do the work, government steps in and [private sector] pays the bill.
Sometimes we’re too trusting or too nice.
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Person One Again
The command post in [Louisiana] is a Unified Area Command, which means that there are incident commanders for each geographic section, which is generally by state boundary. The IC makes the operational decisions. …[The] Federal On Scene Commander (FOSC) … should be making the strategic decisions, including resource allocation.
For a period of time, BP had to sign off on resource allocations. This started to slow the resource response by not just hours, but sometimes days. That [was unacceptable to me].
The … strategic planning cell was made up of 50% BP reps, and they refused to allow the National Guard to be part of the strategic planning process. Once the “strategic plan” was briefed, [it turned out] there was no real plan, and no strategy….
The CG actually hired a team of contractors whose job it was to insure that ICS was followed, and people knew their job as defined by ICS. Clearly, they executed ICS by the book. So, if ICS did not work as well as it should, it was not due to a failure to follow doctrine. Command decision took a long time because of a need to reach a consensus among the command group. This is the same thing I saw in Katrina….
I wish the [command structure made better use of] strategic planners and intelligence analysts, but BP didn’t want them. [Asking] key questions about strategy did not nudge the [structure] towards a strategic plan.
But they did ICS like masters.
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“Ready. Fire. Aim.” is not a bad way to respond to a situation that requires immediate action. Deliberation is important. But so is doing something.
There comes a time however for aiming.
ICS has proven its value countless times. It comes as close to doctrine as anything does in homeland security.
But is there any science to support the claim it is the best way to organize a response to every nationally significant incident?
When is ICS — and its NIMS encasement — the wrong way to go?
