Homeland Security Watch

News and analysis of critical issues in homeland security

May 2, 2013

Catastrophe: Should’a, Would’a, Could’a

“I should prefer Mozart. Mostly I listen to 70s hits.”

“I should eat a hot breakfast, but usually have a powerbar instead.”

“I should work-out three or four times a week, maybe I walk around the block twice.”

Should has become moralistic.  It is typically used as a kind of anti-verb, ascribing — often anticipating — non-action.

I have heard a lot of “shoulds” in regard to the explosion of the West, Texas fertilizer storage facility. The April 17 blast killed 14 and injured more than 190 in the town of 2700.

“We should regulate better.”

“We should put buffer zones in place.”

“We should be more realistic about the threat.”

“We should do a better job sharing what we know about the risk.”

“We should focus more on pre-event prevention and mitigation.”

More plural pronouns than singulars it seems.

According to a November 2012 analysis undertaken by the Congressional Research Service, 6,985 chemical facilities self-report they pose a risk to populations greater than 1,000. There are 90 that self-report a worst-case risk affecting up to 1 million people.

The West facility was not included in the CRS analysis.  They did not self-report — or evidently self-conceive — a worst case scenario that would seriously harm anyone.

As regular readers know I have for a few years worked on catastrophe preparedness.

One of the most remarkable — and absolutely predictable — aspects of this gig is the readiness — preference really — by nearly everyone to define catastrophe as something non-catastrophic.  I saw it again last week and this.  It extends across the public-private divide and every level of government.  When a few of us argue otherwise we are being pedantic, unrealistic, and wasting people’s time.

We should give regular time and energy — maybe five percent of overall effort — to truly catastrophic risks: Global pandemic, significant earthquakes and cyclonic events hitting major urban areas, sustained collapse of the electrical grid whatever the cause. Each of these could have far-reaching secondary and tertiary effects.  In some regions I would include wildfire and flooding. If you have a chemical storage or processing facility nearby that is absolutely worth worst-case thinking now not later.

In many cases the most important issues relate to the mitigation of systemic vulnerabilities that are threat-agnostic.  “Fixing” vulnerabilities can reduce consequences for a whole host of threats, including non-catastrophic threats.

USA Today editorialized, “The Boston Marathon bombings overshadowed the disaster in Texas, but what happened in West was deadlier, and preventing the next fertilizer accident should command serious attention.”

There’s that anti-verb again.


And how I wish I’d, wish I’d thought a little bit more
Now shoulda, woulda, coulda I means I’m out of time
Shoulda, woulda, coulda can’t change your mind
And I wonder, wonder what I’m going to do
Shoulda, woulda coulda are the last words of a fool

Can’t change your mind
Can’t change your mind

Beverly Knight

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Comment by William R. Cumming

May 2, 2013 @ 8:06 am

Well Phil an interesting post and probably reflecting the general view of what should be a catastrophic event.

Respectfully my view as to what is a catastrophe is in fact very different IMO from the norm or your view.

You may remember in past posts on my own blog and comments on yours that under President James Earl Carter’s Reorganization Plan No. 3 of 1978, the newly created FEMA was statutorily [reorganization plans have the force and effect of statute when enacted into law] prohibited from planning for castastrophic events! And OMB ruthlessly enforced this prohibition. Which is interesting since from its creation FEMA administered the Federal Civil Defense Act of 1950 [Public Law 920 the 81st Congress] until its repeal in 1994 by Public Law 103-337. That repealed statute survived as partially incorporated into a new Title VI of the Robert T. Stafford Disaster Relief and Emergency Assistance Act [Public Law 100-707]! But the primary purpose for that statute in part was to protect the public from a full scale nuclear attack by an enemy.

I define a “catastrophe” as any event exceeding the planning basis for protection, prevention, mobilization, response, mitigation and recovery from any incident or event.

Thus, for a local government like WEST, TX, this event clearly exceeded its planning basis for such an event and apparently there was not just a shortfall in the planning basis but no plan at all encompassing such an event.

The George W. Bush administration, perhaps in violation of law, but not after the formation of DHS IMO did in fact start the ball rolling on planning for a castrophe of various kinds. I believe Tim Baden then on transfer from GAO and now an SES in FEMA did some of the early work.

Of course my postion that Reorganization Plan No. 3 of 1978 has been formally superceded by operation of law is NOT repeat NOT the FEMA position or that of anyone else. That Plan is continued to be cited as authority for some FEMA programs, functions, and activities. Compeletely erroneously IMO. Of course I like planning for the MOM [Maximum of Maximums] perhaps another definition of catastrophe.

So where does that leave US? If an incident/event is not planned for thus NO planning basis then it is in fact catastrophic for those involved that did not plan. And even if they did plan capabilities could well be exceeded in a hurry jsutifying close assistance under Mutale

Comment by William R. Cumming

May 2, 2013 @ 8:17 am


Mutual Aid or EMAC! So as a starting point the planning basis capability in any level of government or private entity emergency plan is crucial to understanding how the response will be handled. Unfortunately of course the Planning Basis for most plans does not exist or its actual capabilities.

I have long advocated that Major Disaster Declarations under the Robert T. Stafford Act be confined to events with multistate impacts or where governments have had their own response capability destroyed or after any State has submitted to Uncle Sugar cancelled checks for the event for $10M or some other appropriate amount.

The Sandy recovery is beginning to document that many that should have had property and casualty insurance did not have it. In particular condominium and coop Associations.

So failure to even purchase insurance so that many just hope for government handouts post disaster and this reinforces the notion that disaster relief is an entitlement in the minds of the public.


Comment by Philip J. Palin

May 2, 2013 @ 8:23 am


I would be thrilled to work within the scope of your definition: A catastrophe is any event exceeding the planning basis for protection, prevention, mobilization, response, mitigation and recovery from any incident or event.

I will also readily admit that you and I do differ. Given what most professionals define as a “plan”, I argue that a catastrophe is an event that exceeds the human capacity for planning.

Comment by William R. Cumming

May 2, 2013 @ 9:12 am

Well Phil accepting your position as stated “I will also readily admit that you and I do differ. Given what most professionals define as a “plan”, I argue that a catastrophe is an event that exceeds the human capacity for planning.” then our disagreement continues.

I believe in plans being based on actual authorities and capabilities. The human mind can plan for almost anything except the possibility of his/her own demise or the extinction of the species.

My point rests on the fact that very very few plans anywhere in the USA contain specifics as to triggering and resources currently available without mobilization capability for resources from elsewhere.

And I would argue that none in any level of governmember

Comment by William R. Cumming

May 2, 2013 @ 9:24 am


And I would argue that none in any level of government knows who will show up, what education, training, competencies they have, how they will be funded and equipped and exactly what they intend to do.

This lack of certainty is a huge problem. Looking for the earliest definition of EM I have concluded that in fact mobilization beyond existing planned resources is also part of the paradigm of EM.

As for FEMA what its real capabalities consist of is the provision of funding for others and information. Both those capabilities not particularly efficient or effective. Should FEMA have more capability? That is the question unanswered by any Administration or Congress and never the subject of oversight!

Comment by Philip J. Palin

May 2, 2013 @ 12:32 pm


If we can agree there is a continuum of planning — ranging from the strategic to the operational to the tactical — does your concept of a catastrophe “plan” give more or less attention to any portion of the continuum?


Comment by William R. Cumming

May 2, 2013 @ 1:03 pm

Phil! The entirety should be covered but the most important thing is to self-identify deficiency in planning and capability.

By the way in a length Houston Chronicle article the authors concluded that no legal authority existed in any level of Texas government to regulate the WEST, TX pl
WOW! That is a conclusion to look at closely.

Comment by Philip J. Palin

May 2, 2013 @ 1:11 pm


What does a tactical plan for an innately unpredictable event look like? Or perhaps a better way of asking the question given your framework: What does planning capability for profound uncertainty look like?

Comment by William R. Cumming

May 2, 2013 @ 1:19 pm

Start with an asteroid?

Comment by Philip J. Palin

May 2, 2013 @ 3:00 pm


Okay, help me think through a base planning capability for an asteroid. Until some recent re-calculations, there was concern the 325-diameter Apophis asteroid might target earth in 2029 or 2036. Just as a thinking exercise, let’s assume a 2036 impact has instead been confirmed.

Your framework calls for a planning capability that includes strategy, operations, and tactics related to protection, prevention, mobilization, response, mitigation and recovery.

Is there (legal?) authority in place to undertake the planning? I would say yes. Do you agree?

is there (actionable?) planning capability for each mission-area? I would say yes. Do you agree?

Should there be/Must there be a sequence to implementation of the planning capability? In other words, are there strategic priorities among the mission areas? So, might we give much more initial attention to strategic, operational and tactical plans for preventing; while perhaps we would early-on only undertake strategic planning for response? I think so, but would be interested in your response.

These are authentic questions. I am trying to apply the use-case to understand your approach to catastrophe planning.

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