Homeland Security Watch

News and analysis of critical issues in homeland security

June 8, 2010

Why is NIMS and ICS the one-size-fits-all response to significant national incidents?

Filed under: Catastrophes,Strategy — by Christopher Bellavita on June 8, 2010

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.


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?


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.


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.


“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?

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Comment by Philip J. Palin

June 8, 2010 @ 10:54 am

In my specific experience with ICS and NIMS (limited) and with other management protocols (more extensive), such concepts and procedures are more effective, if:

1. Whenever and however possible the concepts and procedures have been integrated into common — ideally day-to-day — operational contexts.

2. The concepts and procedures have undergone a process of “socialization” (small s) through training, education, exercising, and so on by which the humans expected to practice the concepts and procedures meet each other and engage such expectations in advance.

3. The concepts and procedures are applied creatively and in a manner calibrated to context, rather than dogmatically or bureaucratically.

Comment by Marko Bourne

June 8, 2010 @ 12:34 pm

Please consider this first post as a teaser for more info later.

For the over 30 years the nations emergency management and emergency response entities had more than half a dozen competing incident management constructs, some similar some very different. As a result, multi agency and multi jurisdictional events at times we chaos. Never mind the fact that the public health community, the private sector, and other periferal groups had nothing in the way of an analogos system.

As the first and founding director of the NIMS Integration Center in 2003, as a 27 year first responder (fire, EMS and police) and emergency manager at the local, state and federal levels I watched and lived the ever shifting sands of this discussion.

The current NIMS was NOT created by the Forest Service in the post 9/11 days… there is a much deeper story there regarding the role that the United States Fire Administration played to bring Incident Management Teams from the Forest Service to support the logistics requirement of FDNY. There is a long history that the Forest Sevice, California Fire and others who created FIRESCOPE ICS which lies at the core of NIMS.

Also the decision to build around one base model and pull the best from others was a two year dialog involving stakeholders at many levels inside and outside the government. It was fought at the highest levels in the White House as well. The current NIMS is not perfect, its not designed to be used enmass in ALL events but is designed to be scalable to the needs of the communities.

Later this evening when I have more time I will add to this post with the “backstory” of why it is what it is the nature of what the future could hold for it. After more than half a century with no common system, language or protocol, we are just beginning to see the fruits of adoption and training and education that the next generation of emergency leaders will be far more familiar with than those before. To throw it out now because it may not fit every need all the time is a colossal waste of 7 years of effort, funding and growth.

Much much more to follow.

Comment by Christopher Bellavita

June 9, 2010 @ 5:12 am

Crisisblogger has a related post about the effect of the BP Spill on NIMS and ICS and JIC (joint information ce nter)on June 7th called: not sure how the joint information center can survive this. Very much worth a read.


Comment by Philip J. Palin

June 9, 2010 @ 5:43 am

Chris, I appreciate the link to Crisisblogger, very helpful comment… especially given his focus on the relationship of planning to operating and the implications to ICS and NIMS.

Former Speaker of the House Tom Foley once told me that official Washington shares the folly of medieval nominalists. By this he meant, there is a tendency to see words-on-the-page as accurate reflections of reality (or even reality itself). Too many emergency planners share this folly.

Plans are meaningless — and can even encourage dangerous delusion — unless the plans are the outcome of significant stakeholder input, stakeholder understanding, stakeholder engagement, and stakeholder ownership. Stakeholders include citizens, media, and political leaders. There are always too many stakeholders to ensure that a detailed plan survives more than the first minutes or hours of a crisis.

But if the reality of stakeholders and other unpredictables is built into the plan and various management frameworks (e.g. NIMS), such forethought can contribute enormously to effectively managing a crisis.

NIMS, ICS, the latest, greatest emergency plan, the most exalted HSPD, the most well-meaning legislation… all are only words on a page (or screen), unless and until those involved in implementation mindfully and practically give the words practical meaning.

Such meaning-making is difficult, time-consuming, expensive, imprecise, and irreplaceable.

Comment by bellavita

June 9, 2010 @ 7:14 pm

“Foley” spoke about the “folly of medieval nominalists?” Ah yes, those were the days….

Comment by Mark Chubb

June 9, 2010 @ 10:44 pm

In my experience, NIMS/ICS (and all other similar C3I) systems work best where the desired outcomes are considered self-evident, i.e., put the fire out, find the bad guys, stop the leak. But the system has difficulty when the outcome becomes less clear or the resolution of a problem by technical means does not address the larger issues represented by its occurrence or consequences, especially when the effects experienced as negative externalities. This is especially true in instances where the externalities arise from information asymmetries.

The legitimacy of ICS rests on assumptions about the acceptance of NIMS as a policy-framework for government intervention. I wonder sometimes whether the federal government’s decision to endorse ICS under HSPD-5, which essentially forced its adoption at the state and local levels and across the wider HS and EM community as a condition of receiving preparedness grants, undermined commitment to it before a policy consensus, or at least a constituency for a policy solution like it, had emerged outside the fire service and a few other users of the legacy systems.

Having watched events unfold since the days of FIRESCOPE, I look forward to Marko’s further contributions to this discussion.

Comment by William R. Cumming

June 11, 2010 @ 5:29 pm

I understand HSPD-5 and 8 are under active White House review. Will NIMS survive?

Comment by William R. Cumming

June 13, 2010 @ 11:37 am

Tuesday night Presidential address will seek President Obama developing a new domestic crisis management team, system, and chain of command, IMO!

Also possible Stafford Act declaration as BP funding stream to victims proves inefficient.

Also likely that BP will be asked to escrow $10B for claims and damages, as a start.

Comment by Old Guard

June 25, 2010 @ 12:50 pm

The USCG may have trouble effectively dealing with the oil spill due to the drastic changes it has undergone since 2001. This has led to a loss of those personnel who had buit up an expertise in NIMS and ICS and how to apply it to a deepwater type of situation. The service has gone from one of the most preeminent and customer satisfying federal agencies in Marine inspections (which had included platforms), environmental and marine safety prevention response to one of the less efficient and not well thought of federal agencies in these areas. The below outlines why this has happened.

Right after 9-11-01 the USCG was given or had an old mission greatly enhanced with new duties and emphasis on top of its original now called legacy missions. The agency was also moved from DOT to DHS which fit in with its new security missions but not its legacy missions. This was done without the USCG asking for the real increase in resources to do the new mission and still effectively do its existing missions. The USCG was barely keeping its head above water doing its original missions through the talents and efforts of motivated well-trained staffs. With the additional mission there needed to be about 10-15 thousand more personnel and other resources added to do it effectively. Unfortunately the USCG leadership, who have perpetuated this type of problem over the last 60 years have taken on new missions in a similar fashion. However as the USCG was already at maximum capacity with their original missions something had to give and basically that was the legacy missions and the professionalism in the mastery of the original mission areas that USCG personnel had before the change. What I mean by this is that the average USCG officer or enlisted personnel used to be able to become expert in either a mission area in either the Operations or Marine Safety and Environmental response mission areas. Either of the Marine Safety and Environmental or Operations missions required years to become truly proficient. Other local and state federal agencies used to count on that expertise but are not sure they can any longer. The resent congressional hearings on the lack of satisfaction with the Marine Safety program and the poor showing at the Cosco Busan spill are only a beginning.

The COMDT Admiral Collins at the time and then Chief of Staff of the USCG Vice Admiral Allen (who was the prime architect of the change) started a basic structural change in the USCG that would try to fit in the new homeland security missions with the original missions, savaging in a large part from the original Operations and Marine Safety and Environmental (MSE) missions. They decided to create two very different pathways for advancement, Response and Prevention. instead of creating a third mission pathway called Homeland Security. Officers now have to move from area to area across the two new programs to advance spending little time in each area. This allows them to get only a thin venire of knowledge and no real mastery of the original missions. Most of the time is now spent in the homeland security mission were the personnel will get some limited mastery. The problem with this is the very connected structure that the MSE missions had with regard to career pathways, training, cross communication and mission mastery are now broken. The same could be said of the Operations missions. Many personnel who had that MSE mastery from all levels have left the USCG or retired early and 70 percent of the current personnel in the USCG have been hired since 2001. Ask the USCG for records or retirements in these ranks and look at their backgrounds, you will see a large number of MSE trained personnel that have left. MSE personnel positions have also been downgraded particularly in the environmental area and staffs to do environmental response have been significantly reduced making us vulnerable to be effective in a spill response. The National Response Team Co-Chair in 2008 was changed from a senior Captains billet to a Commanders billet to the anger of the other federal agencies, in part because so many senior people had left the service there was no one else with the background to fill the position. Unfortunately the MSE mission had fallen out of favor. Almost the entire group of USCG Regional Response Team Co-Chairs and Sector Commanders have no or very little MSE background. This could lead to disastrous decisions during an MSE emergency. Oil Pollution Act billets have been shifted to go to homeland security billets. There is not even an environmental major department at the USCG headquarters office. Essentially the USCG is now a homeland security organization and will do that very well. The original missions are sun setting. Enlisted personnel are advancing in rate so quickly that the Senior enlisted personnel cannot be counted on to provide that hands on depth of knowledge and on scene decision making that was a given in the past.

There are personnel in many command positions in the new sector organizations who have no solid original missions backgrounds especially MSE and a competant understanding of NIMS. And this continues into the breadth of the organizations. There are very few if any personnel in district offices and at the Admiral level who have any depth of background in or understanding of the MSE missions which used to be more than half the USCG operations and budget.

The USCG has never had a stellar planning program. They have never had a pathway for their enlisted and officers in this area as other services do and it has contributed to their overall problems. The deep water debacle and the above are a symptom of this.

There are not any quick solutions. So much MSE mission depth of knowledge has left the USCG that it will take years to get the agency back to where it was. What needs to happen is to reverse the new rigid stove pipes of Response and Prevention and bring back a modified MSE and Operations mission with a new Homeland or Port Security mission at each unit, district and at USCG headquarters, with the resources to do it. The USCG also needs to develop a true planning program and pathway in the USCG. The other alternative is to split off the Prevention/MSE mission from the USCG and give its money, personnel, resources, navigation aids vessels to DOT to run the program.

Comment by Philip J. Palin

June 26, 2010 @ 8:40 am

Old Guard, Thanks for the detailed comment. I am concerned that unless you are directing readers to your comment it will not be seen by many. I have seen it only because of the way the Homeland Security Watch “back office” displays comments made to any post. There is no way for me to contact you directly, but if you happen to see this comment… will you give me permission to edit-a-bit and copy-and-paste from your comment to the front page? I don’t know when I might do this, probably depends on what else is happening.

Comment by Old Guard

June 28, 2010 @ 10:45 am

Phillip, Yes but please keep it in context. The USCG needs some help and direction. I think Congress would be willing to give it the resources if asked, but the USCG is going to have to rethink its structural change back to somewhat of what it was before as i indicated in my posting to get back its expertise and respect for mastery in its legacy missions.

Comment by Old Guard

June 29, 2010 @ 5:32 pm

To answer his question about if the system is the best to use, it depends. ICS is not NIMS, it is a part of NIMS. There are three legs to the NIMS doctrine, the Multi Agency Coordination System (MACS), the Incident Command System (ICS) and the Public Information (PI). All three need to work well for it to function at capacity. There are approximately only a few groups and agencies that use NIMS on a regular basis in large incidents to be able to function well in it, the Forest Service, the Wildfire responders and Some metropolitan Fire Responders and parts of the Department of the Interior. For any system to function well people have to understand the system and have practiced and experienced it regularly. Most federal agencies outside of the above have little knowledge of the use of Area Command (AC), Unified AC (UAC) and MACS. States and counties have creditable MACS in the Emergency Operation Centers and Dispatch Centers. Unfortunately the USCG and many other of the federal agencies do not have this experience as they have not really made it a part of their daily operations and do not do it enough to become competent at it for large scale operations. The USCG had a further impediment with most of their personnel who had an experienced understanding of the NIMS process having left over the past 9 years. There has been allot of talking about using NIMS but very little action to make it the system that is used consistently/daily. So no wonder FEMA struggled in Katrina with a new plan an almost nonexistent, untrained in the new system, low staffed (about 2000 personnel, many new) agency. The USCG is experiencing the same turmoil but some saving grace to fall back on its military discipline, not ICS, like it did during Katrina. When you get into a Unified situation it becomes further muddled unless the partners in command understand the system. NIMS can work in any situation, like any good system, but you have to have practiced with it and be competent in the use of it.

FEMA is trying to develop new NIMS tools and policies as they did not develop many initially over the last 5 years as they were concentrating on the ICS side of NIMS. They have their own internal problems with their Joint Field Offices (JFO) where they are trying to use an ICS tactical response structure in a MACS organization which causes some confusion.

There is allot of growing to do with NIMS and if we are serious, we need to develop experienced personnel in the various parts of NIMS to make it truly work well. It took the forest service 30 years of commitment to the system to get the expertise to be where it is today. It will not happen overnight and if we fight it or play at it, it will end in confusion and people getting hurt or worse.

Comment by Harold

October 9, 2017 @ 9:41 pm

?Quality is everything, so we need to ensure that there are values on what we are sharing to keep our subscribers interested.

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