Homeland Security Watch

News and analysis of critical issues in homeland security

October 29, 2010

Perspectives on Preparedness: Nudging us forward bit by bit

Filed under: Preparedness and Response — by Philip J. Palin on October 29, 2010

On Wednesday Mark Chubb offered a considered critique of the recently released Report to Congress: Perspectives on Preparedness (large PDF). 

In particular Mark noted, “It is not too hard to imagine myriad new federal strings being attached to the dollars flowing from federal coffers to state, local, and tribal authorities.  Previous investments that sought to promote material improvements in preparedness will likely be replaced by new process-oriented requirements without achieving the desired alignment or shared sense of purpose.”

While this threat is nearly omni-present, there are several recommendations in the report which attempt to mitigate the threat. Further, here’s one of the recommendations made by the Local, State, Tribal, and Federal Preparedness Task Force that is clearly aimed at more direct material improvements in preparedness.  From page 24:

One promising new preparedness initiative involves incentivizing individuals to take action by providing tax breaks for preparedness investments. We therefore recommend that all levels of government consider establishing financial incentives to encourage individuals, families, and businesses to undertake preparedness activities. The underlying logic is simple: prepared citizens minimize the potential costs of disaster and reduce the strain on first responders during a major event. The science is similarly encouraging: behavioral economists widely recognize that minor financial incentives can succeed in motivating individuals to make life-affirming decisions where even the risks of abstract, severe consequences cannot.
Moderate investments of time, energy, and resources to address potential problems before they occur can achieve significant savings in the long run. More importantly, incentives create an artificial imperative in the absence of perceived threats or hazards. Incentive-based approaches may be valuable in regions prone to less frequent, but potentially catastrophic incidents. Compliance with mitigation efforts such as structural reinforcements in hurricane or earthquake zones, or defensible space in the case of wildfires, should produce tangible rewards in terms of property value, tax breaks, or insurance rebates. In fact, some States—including Virginia and Louisiana—are already complementing their existing preparedness programming with tax incentives to encourage citizens to act.

Both Virginia and Louisiana combine tax incentives with a specific communications strategy. Early in hurricane season both states sponsor annual tax holidays for purchasing season-specific supplies.  The Virginia list of tax exempt products is available from from the Commonwealth’s Department of Taxation website.

This is a simple, low-cost, and easy-to-administer approach to encouraging citizens to do what they already recognize they should be doing.  It is a nudge in the right direction.  Packaging the timing, message, and nudge is a good example of “market-oriented” behavior by the government.  The private sector amplifies the message with advertising to sell the tax-exempt products.  Win-win-win.

Tax policy is regularly used to nudge us.  Tax deductions and credits encourage home buying, energy conservation, charitable giving and much more.    Tax credits can be especially motivating.  A tax credit is a sum subtracted directly from the total tax to be paid. 

The Commonwealth of Virginia — widely considered a conservative leaning state, especially in regard to tax policy —  offers thirty tax credits.  These range from encouraging “Agricultural Best Management Practices” to “Historic Rehabilitation” to “Long-term Care Insurance” to “Land Preservation” to the construction of “Riparian Waterway Buffers.” 

There is not yet a “disaster preparedness” or better yet a “resilience enhancement” tax credit.  What would one look like?  Here’s the Virginia Department of Taxation description of the Agricultural Best Management Practices tax credit:

This credit is available to individuals and corporations that are engaged in agricultural production for market and have a soil conservation plan in place to provide significant improvement to water quality in Virginia’s streams, rivers, and bays. To be eligible for the credit, your plan must be certified in advance by your local Soil and Water Conservation District.

The credit is 25% of the first $70,000 you spend for approved agricultural best management programs. The maximum credit is $17,500 or the taxpayers’ tax liability, whichever is less. Unused credits may be carried forward for five years.

Individual filers complete Schedule CR, Part XIV, and corporate filers complete Form 500CR, Part XVI to claim this credit. Attach the certificate from the local Soil and Water Conservation District from the locality in which the credit is claimed.

Reference: Virginia Code 58.1-339.3

Reference: Virginia Code 58.1-439.5

The key element is the plan being certified by the local Conservation District.   I have long advocated the Citizen Corps program looking to the soil conservation movement as a model.   It is a fantastic success story emerging from the catastrophe of the Dust Bowl.  The soil conservation movement  features strong public-private partnerships, great local, state, and federal involvement, and significant connections with the academic sector as well.  It is participation, collaboration, and deliberation in action.

Local Citizen Corps Councils could certify disaster plans, resilience plans, tabletops, exercises, and more.  In my experience the vast majority of people value — even enjoy — participating in these processes and activities.  But we need some modestly practical nudges to actually do what we want to do.

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Comment by Arnold Bogis

October 29, 2010 @ 12:41 am

You want “practical nudges?”

Mr. Palin, let me introduce you to Messrs Thaler and Sunstein:



Comment by Arnold Bogis

October 29, 2010 @ 12:47 am

I would also like to add a link to suggestions along similar tax-related lines from John Solomon:


Comment by William R. Cumming

October 29, 2010 @ 2:27 am

Just noting for the record that almost 100-140M Americans operate legally outside the federal tax system or state tax systems largely due to poverty. The Earned Income Credit is the largest reason many who otherwise would not be required file returns do so. Property/Casualty insurance premiums also should be looked at more closely for tax consequences. For example premiums for the federal flood insurance could be made deductible thereby reducing free disaster outlays which for individual assistance now are at the non-means tested level of approximately $35,000 per event.

Comment by William R. Cumming

October 29, 2010 @ 2:29 am

And of course the casualty loss provisions of the IRC should be studied more closely. Basically uninsured losses exceeding 10% of AGI are deductible.

Comment by John Comiskey

October 29, 2010 @ 5:35 am

Nudging and grant crack-homeland security 101

Chris Bellavita raised the question what is homeland security?

Many including myself thought the answer was knowable and now ponder ad naseum the true meaning of the term.

I have since invoked cop 101-follow the money:

Nudging i.e. tax breaks incentivize people to do things that benefits the government and the populous.

Grant money does the same thing albeit on a government to government or government to agency level.

Sam Clovis calls the federal governments grant strategy “grant crack” and an emergence of a new federalism. [see http://www.hsaj.org/pages/volume2/issue3/pdfs/2.3.4.pdf%5D

Might nudging reach a “nudging crack” status?

Can we sustain funding streams for grants and nudging?

Similar to allowing lotteries as exceptions to government gambling enterprises in the name of education funding which would have been funded in whole by the government,
grants and nudges are a means to incentive citizens to do what the government wants while the government taxes those same citizens(or other citizens) another way.

That said, nudging and granting is pragmatic.

Just the same, how about incentivizing self-reliance –“self-reliance crack” –the more you do for yourself the more the government can govern without undue taxation –nudging and granting is expensive.

Comment by Claire B. Rubin

October 29, 2010 @ 6:32 am

As a Citizen Corps member, I think you are overestimating the ability and willingness of members to do the work you suggest.

Comment by Philip J. Palin

October 29, 2010 @ 7:17 am

Claire, I absolutely agree with you if Citizen Corps continues to be conceived as current.

As an early step, I think it would be helpful for the FEMA head of community preparedness to have a long lunch with the executive director of the Soil and Water Conservation Society (voluntary membership organization), the USDA’s director of the the Natural Resources Conservation Service, and the USDA historians office.

The full range of services and extensive network of soil and water conservation emerged over time. Today it would be impossible for legislation to depend on the Citizen Corps in the way we see the Virginia statute depending on the Conservation Service. But ten years from now…?

There are, I think, important lessons learned from how we engaged participation, collaboration, and deliberation in handling the dust bowl catastrophe that could be applied to avoiding another catastrophe (or two).

Comment by Philip J. Palin

October 29, 2010 @ 7:23 am

John, As we have seen so dramatically in the housing bubble: yes, nudging can also encourage addiction to false hopes of security. But… one of the reasons I am pointing to the soil conservation movement as a model is that we can learn from its over 70 years of success, foibles, and failure. It seems clear to me that cumulatively the soil conservation movement has produced a much more sustainable, secure, and resilient nation. Valuable analogies abound for homeland security.

Comment by William R. Cumming

October 29, 2010 @ 7:46 am

SCS personnel are represented at the local level by Extension Agents. No such deployment exists for FEMA staff which to some degree remains social isolates in their various geographic locations. And perhaps no surprise FEMA is spread out more widely than you might think just not down to the County Extension Agent level. It is only in recent days that FEMA has started to reach pre-Katrina levels of permanent staff but again that staff is not deployed to the local level except during declared disasters.

But guess what is deployed locally and has time on its hands between call-outs–The FIRE SERVICE! This component of PUBLIC SAFETY could be doing much more community outreach as opposed to developing cooking skills. Is the disability retirement of FIRE SERVICE personnel still hovering near 20-25%? This is not a slur but a question and wondering exactly what has been done to study that issue, even while 2/3 of all FIRE SERVICE personnel lack SCBA!

Comment by Dan O'Connor

October 29, 2010 @ 10:30 am

IMHO there is no amount of funding or incentivizing that will remedy the lack of preparedness. Quite frankly, there is a large amount of data that strongly suggests incentives do not work. Most particular for me;

http://www.danpink.com/archives/2009/07/money-cant-buy-you-performance. http://www.econtalk.org/archives/2010/08/daniel_pink_on.html

The approaches I see here remind me of military medicine…. Lowest level symptomatic prophylaxis and treatments that never get to the root cause… Give em a Motrin! Perhaps a bit of an overstatement, but more truth than fiction.

I think all organizations, like people tend to overstate their capability, understate their ineffectiveness, and avoid the harsh reality of a hand in their own success and relatively, their demise.

Having grant money and/or subsidized compliance never addresses the needed behavior modification. The subsidized compliance part is especially effacing; it metastasizes into further needs in lieu of affecting change.

And, the entire grant process SNAFU is so gamed and ginned up, it’s a wonder anything happens at all.

To some degree and with some regret and egg shell walking; the grant process could be construed as perpetual welfare. It was never meant to be a way of life but it never corrected the malady it was purposed for.

And in the growing risk averse culture more and more “requirements” appear on the horizon and in order to meet the needs of the grant process, a certain degree of compliance is needed…hence the addiction cycle.

I am not trying to be flippant or demure in this response. But this is my case in a nutshell;


Cameras do not prevent crime, yet, initiatives like the LMSI (Lower Manhattan Security Initiative) and other CCTV and surveillance projects require grant money to fund. Copious amounts of money. Once their funded and require maintenance, or obsolescence sets in, (usually 18 months) more money is required to remove, replace, and/or augment with the latest technology. More grant money is needed still… and the cycle continues … but accomplishes little if anything in terms of preparing and protecting the citizens it observes.

I do not believe you can incentivize resilience. You either get it or you don’t.

Comment by Philip J. Palin

October 29, 2010 @ 12:38 pm

Dan, I largely agree with your observations. In the vast majority of cases I even agree with the (non) outcomes you describe. Where I am more optimistic than you is when tax incentives (or even grants) are used in combination with other pre-conditions. These pre-conditions are very much tied to Ostrom’s theory — and the soil conservation movement’s practice — of participation, collaboration, and deliberation. Where there is effective P,C, and D I have seen resilience readiness… and just a bit of incentivization is helpful to move folks from readiness to action. But without authentic participation, collaboration, and deliberation… then your skepticism is, I will readily agree, on target. Grants and tax incentives alone will not generate meaningful participation, collaboration, and deliberation and these are sine qua non.

I apologize for the delayed display of your comment. Evidently the spam filter on the site perceived something potentially threatening. Your comment was being held in limbo until I came back onlinee after my mid-day meeting.

Comment by Dan O'Connor

October 29, 2010 @ 1:11 pm

Potentiall threatening…as deemed by the spam filter!!! awesome.

“We can’t solve problems by using the same kind of thinking we used when we created them.” Albert Einstein

I think we need to redefine and/or re construct incentives and/or grants in order to yield the effectiveness one would hope for.

I do not like to be skeptical or dismissive because that would tend to, I think, thwart creativity. On the other hand; “If it walks like a duck, quacks like a duck,…”

We don’t need more, we need better…

Comment by Dan O'Connor

October 29, 2010 @ 1:13 pm


Comment by William R. Cumming

October 29, 2010 @ 1:53 pm

GAO released on October 29th a periodic report to Congress on FEMA’s preparedness analytical capability which destroys the underpinnings of the document referenced at the beginning of the POST. It does however not discuss that document and fails to indicate that GAO has knowledge of the January 2009 National Preparedness Report issued at the end of the Bush Administration in compliance with PKEMA 2006.

The GAO report in its footnote #1 does point to the definition of “capability” that appears in PKEMA 2006, which is a very useful definition. See next comment.

Comment by William R. Cumming

October 29, 2010 @ 2:04 pm

Extract from PKEMA 2006

“Subtitle C—Comprehensive Preparedness


In this chapter:
(1) CAPABILITY.—The term ‘‘capability’’ means the ability to provide the means to accomplish one or more tasks under specific conditions and to specific performance standards. A capability may be achieved with any combination of properly planned, organized, equipped, trained, and exercised personnel that achieves the intended outcome.”

I find this definition extremely useful when examining issues of the paradigm of “resilience” including those paradigms contained within of (1) Prevention; (2) Protection; (3) Preparedness; (4) Mitigation; (5) Response; and (6) Recovery.

Assuming that term is a controlling factor in analysis of each of these paradigms I would argue that NO capability has been proven for each of the paradigms above. This is not just definition but as the “capability” definition includes, the key component of “specific performance standards”!

Nice job GAO in continuing to identify the fact that few of the 22 goals identified in their Spring 2009 analysis have been achieved despite what the Task Force reported. As always ignoring the use or ruse of use of the term “substantial progress” in any FEMA or DHS report is the correct approach when deciding actual capabilities.

Comment by William R. Cumming

October 29, 2010 @ 2:07 pm

A final note on this theme! Instead of working towards actual capabilities or resilience, we have a system of governance that hopes to pin the blame on someone else when the lack of those capabilities or preparedness or whatever are shown by real world events to have continued to leave the cupboard bare. Please continue to open the doors of the Cupboard HLSWatch?

Comment by Philip J. Palin

October 29, 2010 @ 2:39 pm

The GAO report referenced by Bill Cumming is available at http://www.gao.gov/products/GAO-11-51R

It is an important report. It does not, in my judgment, destroy the underpinnings of the task force report.

I value analysis. We need it. We should pay attention to it. But alone analysis creates nothing and, too often in my experience, analysis — precisely because it tends to break experience into pieces — can be destructive. Analysis has value within the context of participation, collaboration, and deliberation. Analysis of the parts has value within the context of the whole.

I especially value the issues that Bill and Dan are raising and wish I had more time for the discussion today. For now I will encourage your attention to a new book by Kwame Anthony Appiah: The Honor Code: How Moral Revolutions Happen. More available at http://books.wwnorton.com/books/The-Honor-Code/

In his reivew of The Honor Code Jonathon Haidt writes, “The normal, or default, mode of human cognition, for example, is holistic, beginning to see relationships among elements, but people in (the West) think more analytically. They see a world full of discrete objects, like balls on a billiard table, whose properties are best analyzed individually.” This is not an approach that facilitates progress in achieving resiliency, which in this case I think all of the discussants (so far) agree is a worthy goal.

Analysis has its obvious strengths. I am not arguing it be put aside. But if we are really trying to solve problems and seize opportunities analysis is not where we should begin. We ought start with the kind of participation, collaboration, and deliberation that was at least earnestly attempted by the preparedness task force.

Comment by Dan O'Connor

October 29, 2010 @ 3:13 pm

Too often we focus purely on analysis—and the identification of facts—and ignore synthesis, which should occur organically during analysis.

Perhaps it’s our growing litigious nature or simply trying to deconstruct the data into its meta data.
Perhaps Emanual Kant and his thoughts on thesis, antithesis, and synthesis would be better suited.

Often stated as the Hegelian dialectic, it’s a comprising of the three dialectical stages of development: a thesis, giving rise to its reaction, an antithesis, which contradicts or negates the thesis, and the tension between the two being resolved by means of a synthesis.

The thesis being the intellectual proposition, has its negative or antithesis pressed against it, causing that tension, friction, or creative moment to either create or discover a synthesis or solution to the proposition.

There’s also Boyd’s work on Destruction and Creation; http://tinyurl.com/2e8ayao

All things must be destroyed in order to create anew. Oversimplified, but correct in my view and harkening back to the Einstein quote from this morning.

And what of cognitive or operational paralysis?

Paralysis by analysis is much more common than most would believe. The term “paralysis by analysis” refers to over-analyzing (or over-thinking) a situation, so that a decision or action is never taken, in effect paralyzing the outcome.
A decision can be treated as over-complicated, with too many detailed options, so that a choice is never made, rather than try something and change if a major problem arises. A person might be seeking the optimal or “perfect” solution upfront, and fear making any decision which could lead to erroneous results, when on the way to a better solution.

This could also be construed as “death by staffing”.

This phenomena is the most crippling leadership trait one can suffer from in an exigent leadership circumstance or crisis.

And of course, crisis; terrorism, catastrophe, regional interruptions, emergencies, deviation from routine, etc all have exigent requirements innately woven into their existence.

On some level, connecting the theme post and the current meme; Does planning and creating analysis in a vacuum, a static state if you will, in hopes of gaining accreditation and receiving funding always answer a moment in time that has already passed by, thereby rendering a solution to a question that time has since passed?

Comment by William R. Cumming

October 29, 2010 @ 5:57 pm

Phi and other commentators! Question? What do you make of the graphic on page 7 of the GAO report? I have never seen anything like it anywhere before. Am I correct in that passage of time post incident resulting in increased STATE and their local governments preparedness? Does that make sense if it is the case? And what does the graphic indicate about FEDERAL preparedness?

Comment by Claire B. Rubin

October 30, 2010 @ 2:34 am

Bill and I have discussed the graphic briefly. I think it warrants a separate posting on your site.

I find it baffling and troubling. I would welcome comments on it.

Comment by Bill Eller

November 5, 2010 @ 10:07 pm

Mr. Palin:

Interesting that you point to the conservation districts as an example that Citizen Corps could follow to move us forward with local citizen preparedness efforts.

As a graduate of the Masters program at the Center for Homeland Defense and Security at the Naval Postgraduate School in Monterey, CA, I wrote a thesis this year entitled “Leveraging Rural America in the Fight against Terrorism in America through the Use of Conservation Districts.” The url is https://www.hsdl.org/?view&doc=120260&coll=limited.

My focus was on how conservation districts could be used in intelligence gathering efforts in rural areas, but I made a number of the same points as you about the strength of conservation districts as a division of local government – “The soil conservation movement features strong public-private partnerships, great local, state, and federal involvement, and significant connections with the academic sector as well. It is participation, collaboration, and deliberation in action.”

While the Extension Service is a great educational resource, they do not have the same “boots on the ground” everyday contact with rural landowners, farmers and ranchers that conservation district staff and supervisors do. I don’t want to belabor the point, so please read my thesis if you want more!

I am a staff member of the Washington State Conservation Commission, the entity that has oversight responsibilities for the 47 conservation districts in Washington State. I recently proposed using the districts, who already do conservation planning for farmers and ranchers, to include an element of emergency preparedness, mitigation, and response and recovery planning into the services they already provide.

Districts exist in every state, and they are lead by locally elected boards of supervisors who are typically farmers, ranchers and landowners in the local community themselves. I believe they could be a great resource in the GWOT / for disaster preparedness — not only in rural areas, but in urban centers as well (they serve any landowner with a resource issue in their district boundaries, regardless of status as a farmer or rancher).

I would be very interested in any further communication, ideas, or collaboration on using the highly successful conservation district model for local citizen preparedness efforts. Please feel free to contact me at my email address: beller@scc.wa.gov.

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