Homeland Security Watch

News and analysis of critical issues in homeland security

April 9, 2011

PPD-8 as a natural evolution of HSPD-8

Filed under: Preparedness and Response — by Philip J. Palin on April 9, 2011

I do not read PPD-8 as a repudiation of HSPD-8.  It can even be seen as renewing attention to the fundamental purposes of HSPD-8. Given the comparative paucity of officially promulgated Presidential guidance in this administration, the priority attention being given to preparedness is, at least for me, encouraging.

The December 2003 document directed development of  a “national domestic all-hazards preparedness goal” to include, “readiness metrics and elements that support the national preparedness goal including standards for preparedness assessments and strategies, and a system for assessing the Nation’s overall preparedness to respond to major events, especially those involving acts of terrorism.”  The new PPD is entirely consistent with this purpose.

The new PPD is also an important reframing of strategic intent. What is new — and important — in PPD-8 is the inclusive character of the goal-development process and the focus on capabilities-based planning.

The capabilities-based focus comes closest to a repudiation of past practice.  In part — but only in part — this is direction to stop requiring every county, village, and such to organize its preparedness around all fifteen national planning scenarios.

As Brian Kamoie emphasized in his Friday remarks at the Homeland Security Policy Institute, this is not a rejection or even a critique of the national planning scenarios.   But it returns the scenarios to what I perceive was their original purpose as provocative touchstones for thinking and training.  The scenarios have gradually morphed into the foundation of a nationwide threat-based planning regime that too often distracts from — and even discourages — authentic local and regional risk analysis.

But the focus on capabilities is much more important — and creative and positive — than correction of past practice.  In his influential 2002 monograph for the Department of Defense, Paul Davis explained that capabilities-based planning is:

  • A conceptual framework for planning under uncertainty by emphasizing flexibility, robustness, and adaptiveness of capability.
  • An analytical framework with three components:1) understanding capability needs, 2)assessing capability options at the level of mission or operation, 3)choosing capability levels and choosing among capability options in an integrative portfolio framework that considers other factors (e.g., force management), different types of risk, and economic limitations.
  • A solution framework that emphasizes “building blocks.”

Where PPD-8 especially expands the scope of  HSPD-8 is in its embrace of non-governmental capabilities.  There is much more emphasis on involving “everyone”.   It does not reject the good work achieved since 2003, but PPD-8 certainly encourages an aggressive outreach effort to “galvanize action” and to facilitate an “integrated, all-of-Nation, capabilities-based approach to preparedness.”

When I read the PPD in the context of Brian Kamoie’s explanations, a variety of remarks by Craig Fugate, and my own experience what I take away is something close to: Preparedness will always be insufficient and unsuccessful if it focuses mostly on what the government can do.  Government’s most important role is to involve, engage, collaborate, and deliberate with the non-governmental sectors.  Preparedness is primarily a non-governmental function.

If this is an accurate interpretation, I agree and admire the courage and intelligence of the policy guidance.  I also wonder and worry if there is a realistic understanding of the strategic, operational, and tactical challenges (and changes) this implies.

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Comment by John G. Comiskey

April 9, 2011 @ 6:22 am

So, what does PPD 8 mean? As a local practitioner it used to mean [to me]: okay let’s see if PPD-8 is funded and how much do we [locals] get and what can we do with the $.

Academically, the same question has other dimensions that are triggered by my mandate to analyze what PPD means. Yesterday, Philip Palin asked bloggers to “be prepared to consider preparedness. So, I considered and wondered as I watched the Homeland Security Institute discuss PPD-8. Afterwards, I reviewed my lesson plan for an undergraduate intelligence class. On topic was a review of Bloom’s Taxonomy to preface an examination of the 2007 NIE on Iran’s Nuclear Capabilities.
As we progressed from analysis to synthesis to evaluation, one student questioned the efficacy of identifying the components of topic and then “creatively” putting the components back together so as to evaluate. I pondered that question and reflected on my own struggle with the ambiguities of intelligence “tradecraft.” Renown intelligence expert and author Mark Lowenthal wrote “in government and intelligence we assent to a degree of ambiguity.” I have invoked that precept in graduate classes only to be rebuked with frowns. [My post-class notes emphasize using a different approach ….still looking for a qualifier]

To the analysis:
First, while I understand the historical precedent and constitutional interpretation, absent a clear and present danger, do presidential directives “statutorily” have the force of law? [I am not sure -but believe they should be simply because, IMHO, our Executive is too weak for 21st century governance.]

Second, [related to last qualifier], IMHO, we hold our Federal government to governance and services that are statutorily prohibited. George W. alluded to this in Decision Points but opted to accept responsibility for Katrina. [The buck stills stop here {mostly}]

Third, [also related to our Federal system of governance and not our National system of governance]. No mention of education. A culture of preparedness starts with a K-12 education that emphasizes, civic responsibility and rights, Emersonian self-reliance, resiliency, and PREPAREDNESS.

Fourth, I did here mention of streamlining in yesterday’s discussion. No mention of streamlining in PDD-8 nor National Preparedness Guidelines. [ugh 2.0]

Fifth, kudos to the definitions -words matter!
Semper Paratus

[I learned that Latin on day one of USCG boot camp -mostly you have to grow up we “ask” 17 year olds to do so -why not us all?]

Comment by Philip J. Palin

April 9, 2011 @ 7:40 am

John, In my view Presidential Policy Directives are mostly explicit statements of administration priorities.

As head of the executive branch, the President can — within the bounds of the law — set the direction, tone, and approach to be used across the cabinet departments. A written document gives White House staff a bit more leverage in doing their interagency work.

When I was still CEO (of a minuscule organization compared to the federal government)I would from time to time try to articulate goals, priorities, choices, and trade-offs that the organization should attempt to advance in daily work. I see the PPDs as very similar.

This is one of the reasons I especially value the brevity of PPD-8. Huge organizations are led, if at all, with a few simple concepts. Even in the case of a few, well-articulated, and expertly executed concepts large organizations mostly ignore leadership. But clarity of attention improves the chances of progress.

Comment by William R. Cumming

April 9, 2011 @ 9:57 am

Well PHIL a useful post and yes despite the recission language I agree that HSPD-8 and its Annex are still of utility.

But I detect some finger pointing and blame shifting in PDD-8. Basically it does not explain nor does any explanation exists as to what the STATES and their local Governments, NGO’s, the private sector can expect in the way of PREPAREDNESS from their federal government. In other words no one still knows Who will show up; What their training and competence will be; What their funding will be? What their logistics and mobilization and surge capability will be: How long they will be around and will they operate 24/7/365 or in some other fashion. Does no one but me think the certainty of formal disclosure on these items is of significance. Japan is answering them now and in the context of an actual event or events depending on how you analyze it. So before stating that preparedness is everyone’s job how about the federal government explaining in clear text and language what it can and cannot do. A book could be written on this subject I fully understand. And I believe a book will be written post-event describing exactly what happened and why! Perhaps this is optimistic because I would argue no single books or even number of them have been written on Hurricane Katrina and its aftermath that delves into the why and wherefore of the event. The USACOE is still in litigation arguing for immunity under 33 USC Section 701-03 and that outcome is unknown. We do know that the USACOE in a document issued by the Water Resources Center in Vicksbury, a USACOE facility issued an amazing MEA CULPA doc several years ago.

So time for nitty gritty. I note that 2/3 or more of the DHS was deemed essential and not to be furloughed while 90% of EPA was scheduled to be furloughed. Does none in the Administration understand that EPA is largely the technical civil response agency for the federal government along with CDC and that DHS has little in the way of civil reponse technical assets unless you consider the US Coast Guard.

And by the way the recently released report [March 2011] indicates at least 10 major issues involving preparedness stemming from lessons learned from the BP catastrophe but of course not reflected in PPD-8 which is largely product TBD [To Be Developed]!

I am now upgrading my analysis for the Japanese event to a two decade effort? I can argue my case and wonder what others think if the FEDS were forced to take on that kind of task? And again I don’t believe that the Japan event was a Black Swan.

Comment by Philip J. Palin

April 9, 2011 @ 11:17 am

Bill, For what it is worth, I perceive that DHS — and FEMA in particular — is doing a great deal of work and making real progress on addressing the issues you raise in the second paragraph above. I don’t think the PPD is the place to deal with these issues, but I hope the process set out in the PPD will produce the desirable outcomes you have identified.

From my perspective there is also an inherent tension in the outcomes being put together. This probably explains some of the current lack of clarity.

On the one hand there is audacious work being done in Bill Carwile’s shop trying to scale-up to deal with pretty wild maximum-of-maximums. If anything, this effort sometimes causes me to worry about strategic hubris… but I do not doubt the earnest good faith of those involved.

On the other hand there is a growing recognition of the innate limitations involved — especially after-the-fact — in responding to a potentially catastrophic event. I am hearing and seeing some intellectual humility that strikes me as very healthy. The “whole community” effort, in a way, reflects a realistic awareness of our official limitations.

For me the PPD is much more aligned with the latter than the former, and that is appropriate for a preparedness policy statement. Preparedness should lean toward worst-case thinking. What if local capability is overwhelmed? What if national capacity is seriously compromised? There is still a role — an even more important role — for preparedness.

While you and I may disagree on the appropriate scope for a PPD, we apparently agree on whether or not the earthquake-tsunami-nuclear emergency was/is a “Black Swan.” Something like it was fully anticipated, was specifically predicted (just in a different location), and several steps were taken to mitigate and manage the eventuality. Some of which worked well, others did not. Maybe a “Gray Swan”?

Comment by William R. Cumming

April 9, 2011 @ 12:34 pm

Phil! Respectfully there are always those individuals in almost any organization trying to do and in fact doing some good work. Clearly Bill Carwile is also running FEMA’s skunk works. But giving speeches and attending meeting does not get the hardnose nitty gritty work of preparedness and developing actual preparedness done. This is tough, time consuming and onerous work. It breaks down the best. Only actual capability when the event occurs meets the test, included the most competent people. W. Craig Fugate, Tim Manning, and Rick Serino worked in rich and at least to some degree well managed states as did their secretary. I have however seen not a single speech where a FEMA or DHS official made comments on the de facto reduction of STATES and their local government’s capability in public safety, EM, EMT, FIRE SERVICE,Public Health etc since Spring 2008. This destruction of capability is a NATIONAL tragedy not just someone elses problem.

And yes a possible “gray” swan in Japan. The effort there is desperate to limit further losses not just to start recovery. And the shortfall in data is enormous and would be repeated in the US in my opinion with STATE RAD HEALTH capability documented as no where near what is needed in many different academic, think tank, and other MSM reports.

The fundamental problem of course is rather simple to me. “IT won’t happen on my watch” attitudes. And we have day jobs to do so don’t have time for preparedness.

So to inject a probably false metric into the discourse–after all the funding and efforts of all levels of government and the NGO and private sector since 9/11/01 I give on a scale of 1-10 with 10 being the highest rating for preparedness, I rate the USA now at a level 2. Remember it is a big nation-state with complicated political arrangements and this goes into my rating. To get to at least a 5 I would need to see a domestic crisis management and response system and chain of command. Close integration of military and DOD assets could possibly raise it to a 7 if NG assets were properly trained and equipped and located in the continental US not elsewhere. But preparedness is 24/7/365 not just periodically available. The forthcoming NLE should be of interest when the players discover how little real operational capability any level of government has in the civil sector. Good luck!

Let’s make the VP accountable for Preparedness and Crisis Management. Subject to the President’s capabilities also. I am hoping that by next fall certain Congressional hearings have been held conducting oversight on what the US has learned from the Japanese experience and always remembering that the Armenian Earthquake and Chernoybl had as much to do with the end of the Soviet Union as Star WARS. And not now going on record, the Japan event is the worst nuclear disaster of all time outside of August 1945 bombings.

Comment by William R. Cumming

April 9, 2011 @ 4:02 pm

PPD-8 says paragraph 44 of HSPD-8 [2003] is not rescinded. Does anyone know what this is referring to?

Comment by Philip J. Palin

April 9, 2011 @ 8:18 pm

Bill, Paragraph 44 amended language in HSPD-5, so the PPD is avoiding un-doing the amendments.

Comment by William R. Cumming

April 10, 2011 @ 8:25 am

Thanks Phil!

Also note this language from PPD-8:

“The NPS shall include a series of integrated national planning frameworks, covering prevention, protection, mitigation, response, and recovery. The frameworks shall be built upon scalable, flexible, and adaptable coordinating structures to align key roles and responsibilities to deliver the necessary capabilities. The frameworks shall be coordinated under a unified system with a common terminology and approach, built around basic plans that support the all-hazards approach to preparedness and functional or incident annexes to describe any unique requirements for particular threats or scenarios, as needed. Each framework shall describe how actions taken in the framework are coordinated with relevant actions described in the other frameworks across the preparedness spectrum.”

One of the reasons I was always an advocate for plan integration was that while technical annexes were definitely required in some cases, the actual personnel that showed up in the real world events and exercises also were often the same personnel. Being able to operate over months in some circumstances means that what I observed was problematic because not enough personnel were available for long term operational crisis management capability.

Looking at the language above I have real concerns as to how many personnel will understand all the various frameworks and plans and will adequate personnel be given the time and training and support to understand what the preparedness system really is in fact not in fiction?

Comment by Potomac

April 10, 2011 @ 1:24 pm

Just what we need, More Frameworks, yay! Let the interagency flogging begin and let the state and local stakeholders stand-by to shift course again and relearn new Federal stuff for the 3rd or 4th time this decade.

Anyone want to start outlining the next Katrina-esque post-incident report? Let me start, “Numerous, hastily developed, and sometimes conflicting frameworks confused, rather than clarified, agency roles and responsibilities…”

Will give credit to NSS, capabilities-based approach definitely better than the scenario-based approach which treated every incident as unique. They are really not, its about recognizing problems as they unfold and coordinating resources to intervene.

Comment by Philip J. Palin

April 11, 2011 @ 5:09 am

Potomac and Bill: In my experience, the deeper frameworks descend into speculative tactical planning, the more they discourage meaningful engagement and spawn confusion. The more they become “fantasy documents”. The more we try to enclose the frameworks prior to an actual event, the less useful they are. So, if this is how the new planning frameworks will be used, I agree with your concerns.

But if frameworks are kept at the strategic level — when they are consciously left open to unfolding reality — they can be conducive to critical and creative thinking under duress. Especially if the frameworks are fleshed out through continuous exercising, rather than through more and more detailed paper pushing.

A capabilities-based approach — that has any integrity with the concept — should remain radically open to what is unknown and unpredictable (which is not to say beyond anticipating). Given the homeland security domain, this approach at least has the potential to be helpful.

Comment by William R. Cumming

April 11, 2011 @ 8:13 am

Well the authors of PPD-8 I would assume would agree with you. My problem is much is wild blue yonder and to be ad hoc’ed like Japan when the BLACK SWAN or some lesser events lands. Since the whole history of national preparedness reflects your point of view I guess I just continue to be a dissenter and don’t believe many would agree with me that we need high reliability preparedness organizations that have done what is humanly possible to do the hard thinking in advance and have the best systems and processes for mobilization and supporting beyond the baseline capability possible. Like General Marshall is reputed to have stated the day after Pearl Harbor–Yesterday we had time and no money and today money and no time.

I have probably identified over 100 unresolved issues on comments on this blog that could be addressed but the powers that be choose not to do so. One of course would be relevant in Japanese type event in the US. That is the relationship if any between compensation and who is compensated under the Price Anderson Act and the “compensation” under the Robert T. Stafford Disaster Relief and Emergency Assistance Act and whether the President believes he has authority to declare a disaster or emergency for a radiation incident/event under the latter act even though it is silent on the terms “radiation” or “radiolological”!

But hey maybe the USA WIll GET LUCKY!

If one of the MSELs {Major Secanrio Event List] suggested for NLE 2011 is played it will be interesting to watch how that is played by the players. And hoping of course there will be some TOP OFFICIALS playing not just wandering around observing that exercise.

Comment by John F. Morton

April 11, 2011 @ 11:17 am

For what it’s worth, one of Brian’s team said to me prior to his presentation at HSPI, “You will hear no surprises.” I took that to mean that PPD-8 was another set of downs that is moving the ball down the field. And that’s a good thing, and no more than within modest expectations, which our current budget crises at all governmental levels impose. Only a Pearl Harbor could have yielded more and found money, maybe, to effect the change/programs. Brian did say during the Q&A something about there not being “Federal solutions” here. Exactly. My mantra has been for the last few years that the optimum homeland security governance structure/process can best locate in the regions via collaborative entities composed of co-equal Federal, state, tribal, territorial, local government IPAs and IPAs from the private sector and NGOs serving in staff positions to prioritize regional risk, develop operational plans, exercise those plans, from which to determine capabilities and capability gaps, set grant requirements and contract from regional centers of excellence (as regional “FFRDCs”) for analytical support thereby to arrive at their own metrics for resilience, sustainability, competitiveness, preparedness or whatever they want to call it. Yes, as was said above, in this networked, globalized, non-hierarchical world, the best service the Federal government can provide is a strategic framework of frameworks, LFA support as one provider along with the EMAC partners and some grant money, SOME grant money, maybe. Washington cannot be THE node. That is called a single point of failure. American HLS governance has got to move from dependency and entitlement to self-reliance and partnership. More Jeffersonian democracy and de Tocqueville. Less Woodrow Wilson, FDR and LBJ. No es verdad?


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