19 Aug 2020
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Script
Hurricanes are a seasonal and a regular occurrence. So why do we put our disaster preparation efforts in the hands of a federal agency that seems surprised and unprepared for each new disaster? FEMA continually fails at training, procurement, contract management, and security? I’ll explore this now…
Folks in North America and the Caribbean look for tropical depressions in the mid-Atlantic. The questions are pretty basic: Will it be a hurricane? Will it hit a place I care about? Will I be impacted? For a decade, I have responded to area damaged by natural disasters as part of my job. The weather service identifies a small low pressure. Dust from North Africa blows east and physics takes over.
Global pandemic… while anticipated and discussed, nobody honestly said: it will hit in November of 2019. Never before have we had a map with red lines and projections and graphs showing us the ebb and flow of a virus. Now we do.
Today, Pandemic Maps and Weather Maps feature prominently in our news outlets. Both impact our planning, thoughts of safety, and how we manage our households and inventory of toilet paper and non-perishable foods.
Please FEMA, tell me what the intersection of a significant hurricane and COVID will look like? How does my 84-year-old aunt in Stuart Florida prepare for this? How do coastal communities prepare for this twinned and intertwined set of calamities?
The local school building with 50-year-old ventilation systems may not actually be safe for elderly, at-risk, and vulnerable folks seeking refuge from a storm. We remember the failures form the 2005 hurricane season. There was no plan then and there was no pandemic.
The scene is set.
FEMA's Mission
To help people before, during, and after disasters
I added the Oxford comma. Link to FEMA’s mission
FEMA's Strategic Plan
- Build a culture of preparedness
- Ready the nation for catastrophic disasters
- Reduce the complexity of FEMA
Let’s look at these three goals under the narrow lens of hurricane preparedness during a global pandemic. There is a tiny chance ANYONE can get this right. Just look at the arguments about opening schools here in August of 2020.
Option 1
Aggregate people into facilities that have supplemental power, a reliable water supply, food, and toilets.
Option 2
Do not aggregate people at all because of the risk of an airborne virus that has killed over three-quarters of a million people globally in eight months.
Choices
Bring people together into facilities that may likely possibly spread the disease.
— OR —
Do not aggregate people and suggest they do what?
FEMA Administrator Letter
The FEMA administrator released a letter to the state directors on the 20th of July 2020. It reads, in part:
“We're in a much different place than we were at the beginning of the pandemic. As a result of our efforts, we've recently seen deaths decrease by 80% within each age group, and mortality rates also continue to decline. Our job, however, is far from over - and now the Sunbelt states need our help.”
The other quote of note herein reads thus:
"We have been here before and we can do it again"
Been Here Before?!?
First, we do not have experience involving success to draw on. A skilled practitioner faces a problem with a suite of successes and failures. There a bit of thinking involved:
- What worked before?
- What didn’t work?
- What do I have at hand?
- What do I need to accomplish?
- How do I get to my objectives?
- What are my contingencies?
My team hears me often say:
- Tell me your objectives?
- How do you know if you succeeded?
- And how do you recognize failure?
- What are your PSTs?
- What is your primary plan?
- Your secondary plan?
- Your tertiary plan?
We plan for two levels of failure when executing a task. And there is an exit plan.
Second, we must study and accept our failures. Sure, I’ve been in dozens, maybe hundreds of FEMA courses and settings. The word failure is not used. We’re supposed to say: Lessons Learned.
That’s bananas. Failures are failures. Failures are a starting point.
Failures don’t become lessons until we actually learn from the experience. Until, repeat the experience again and again and again. The progress from failure to successes with feedback, self-assessment, external assessment. It is then we have learned our lesson. Don’t give me this “Duly Noted” silliness. Performing an after-action assessment and writing the report ought to be ingrained into the culture. I run a software development firm. We do After Action Reports (AAR) with more frequency than you’d imagine – even after being successful. Otherwise, how do you replicate successes; and avoid failures.
Is this a problem at FEMA?
Is forgetting past failures a clue to what may happen? Their websites and training never provide the vulnerability and honesty an AAR requires. Get over yourselves. The best are the best because they study, learn, train, assess, try, and accept failure as progress towards improvement.
At FEMA does not assess its failures. It does not learn from its failures. And it repeats those failures. Let me take you through the proof statements. Additional documents, references, and information is on the website ChristinaMoore.us.
This week, mid-August 2020, my collaborator on this project had a small argument. She said: NOAA just stated this is the worst hurricane season ever. I tried to correct her: Well right now we’re on track with 2005 situation. That’s the year of Katrina and Rita. The ultimate point is that when we look at the 2020 hurricane history and projections, we think “The Worst” or we think “Katrina”. Its about the same, right?
The criticism of FEMA for the response to Katrina was so intense, it has its own Wikipedia page. I am going to pull some of feedback FEMA got from the Congress’ Select Committee on Katrina:
"DHS and FEMA lacked adequately trained and experienced staff for the Katrina response.” “The readiness of FEMA's national emergency response teams was inadequate and reduced the effectiveness of the federal response.” “Long-standing weaknesses and the magnitude of the disaster overwhelmed FEMA's ability to provide emergency shelter and temporary housing.” “FEMA logistics and contracting systems did not support a targeted, massive, and sustained provision of commodities.” “Before Katrina, FEMA suffered from a lack of sufficiently trained procurement professionals.”
That committee included the following in their conclusion:
For years emergency management professionals have been warning that FEMA's preparedness has eroded. Many believe this erosion is a result of the separation of the preparedness function from FEMA, the drain of long-term professional staff along with their institutional knowledge and expertise, and the inadequate readiness of FEMA's national emergency response teams. The combination of these staffing, training, and organizational structures made FEMA's inadequate performance in the face of a disaster the size of Katrina all but inevitable.
Oh, that was so 15 years ago.
Present Day
Let’s step into the present day. You know exactly where I am going, don’t you?
There are no surprises ahead, are there?
What issues topped the list above?
- Training,
- Contracting,
- Logistics,
- Procurement, and
- Some criticism on lack of organizational structure.
In the essay, “75% failure not bad, huh?”, I then ignored the OIG reports related to FEMA. Let’s take a look at a few now.
Recent OIG Reports on Training?
May 2020 | OIG-20-32
OIG-20-32 published May of 2020. This report is entitled: FEMA Needs to Effectively Designate Volunteers and Manage the Surge Capacity Force. Let me define volunteers in this particular use. FEMA used federal employees from other agencies to augment the FEMA workforce because FEMA was unable to staff appropriately. In Puerto Rico, we met IRS employees doing FEMA work. They call those federal employees “volunteers” – I won’t. The term is ambiguous and misleading.
Yes, FEMA entirely depends on a volunteer workforce to manage emergency shelters too. These are typically Red Cross like entities except in some places like New York City where they use the paid employees of the school system as paid volunteers. These people give of their own time and often not paid. I won’t confuse the two.
I am calling the Volunteers Surge Capacity Force: “federal employees”. It is truthful.
OIG-20-32 Findings…
First, FEMA is not effectively designating the federal employee workforce, nor managing them well. FEMA should take additional steps to improve the readiness and management of this workforce.
FEMA did not have a clear commitment from these agencies nor individuals. There was no roster. This is not a cadre of reserve people with go-bags, credentials, and training.
FEMA did not measure their performance. There was no mechanism for reimbursing agencies – no means of validating expenses for accuracy, necessity of costs, nor the reasonableness of costs.
In short, when overwhelmed and stretched thin FEMA was ineffective at managing federal employees brought into help their agency.
Sept 2019 - OIG-19-61
The September 2019 report 19-61 reviewed the New York New Jersey Port Authority for $306 million. FEMA lacks assurance that costs are accurate and reasonable due to the performance of FEMA staff. Here the quote from the opening paragraphs of the 26-page report:
“FEMA should also implement training to emphasize the importance of proper and appropriate obligation of Public Assistance funds”.
July 2019 - OIG-19-55
OIG-19-55 is entitled “FEMA Must Take Additional Steps to Demonstrate the Importance of Fraud Prevention and Awareness in FEMA Disaster Assistance Programs”.
Until FEMA takes visible, substantial, and continual steps needed to carry out its mission programs by detecting and reporting potential fraud in a systematic and timely manner, it will continue to risk the loss and misuse of taxpayer dollars.
I think I’ve made my point on training and some about staffing.
Contracting, Logistics, & Procurement
What is next on the concerns raised following the Hurricane Season of 2005? How about contracting, logistics, and procurement.
This one is just too easy and too numerous!
March 2020 - OIG-20-20
OIG-20-20 is entitled: “FEMA’s Advance Contract Strattegy for Disasters in Puerto Rico”
Further, FEMA did not maintain contract files in accordance with Federal acquisition regulations and departmental or its own policy. This occurred because FEMA’s Office of the Chief Procurement Officer did not have controls in place to ensure contract personnel follow Federal regulations and departmental or its own internal policy.
FEMA already had contact in place prior to the Puerto Rico hurricanes, then found new contracts. 49 of 241 new FEMA contracts were redundant to services already under contract and not used. Oh, dear and look: FEMA did not meet the intent of the Post-Katrina Emergency Reform Act of 2006.
July 2019 - OIG-19-52
July 2019 (report 19-52): FEMA determination of the eligibility of the Puerto Rico power contract with Cobra Acquisitions was not sound and lacked supporting document.
April 2020 - OIG-20-23
My last report on this topic… April 2020 (Report 20-23): “FEMA Has Made More than $3 Billion in Improper and Potentially Fraudulent Payments for Home Repair Assistance since 2003”
Let’s agree that FEMA has not yet learned 2005 failures. The feedback from Congress and the press and even their own OIG echoes and echoes and echoes. I cannot sense improvement.
What Challenges Lay Ahead for FEMA?
Hurricane Plus Pandemic, hum?
It starts with the weather map and that mid-Atlantic low. FEMA like the rest of us looks eastward wondering: what will that become when it grows up?
The Atlantic hurricane season starts on the first of June and progresses through the fall. Hurricanes are fueled by warm water in the tropics, the Gulf of Mexico, and/or the Gulf Stream. Hurricanes are slowed by land masses and cold water.
I may worry about me, or my aunt, or other friends and family. FEMA they have to worry about us all from the U.S. Virgin Islands to Guam. While I am not a student of Pacific storms, they have their stories and seasons too, no doubt. When a storm targets FEMA, the target is very large – what is the number? 330 million Americans.
Mission #1: Build a culture of preparedness
To be fair, many people understand the concept of a go-bag. Some people have a 3-day bag packed that includes toiletries and the like. That’s a FEMA driven message.
Hey FEMA, what are my instructions to prepare for a hurricane during a pandemic? If I need to evacuate… or if my 84-year-old aunt needs to evacuate coastal Florida, what are the instructions? How does she and we prepare for this?
The process of planning, opening, staffing, and supplying shelter is not actually a FEMA job – according to FEMA (until it is). FEMA takes a backseat with gentle guidance and references for training elsewhere – like the Red Cross.
I did pull down recent guidance – one from FEMA and another from FEMA that they republished from Florida. The statement from FEMA reads:
As a direct result of the natural or human-caused disaster, it is necessary to provide mass care and emergency assistance services to affected individuals and emergency responders. In addition, evacuations may be necessary to a neighboring jurisdiction(s) as well as the provision of public health and medical services to individuals affected by the pandemic. This could place an additional burden on neighboring states or tribes providing mass care to the affected populations. Some jurisdictions may not be willing to accept survivors who have, or potentially have been, infected by illness.
The booklet is not actually a plan but a statement of considerations to be included in a plan. As in, if making soup, add salt when you write the recipe. Ok, got it.
2020 Hurricane Season preparedness guidance for citizens? It is not present.
Our nation is not providing consistent and science-based guidance on public health management. And it is also not providing guidance for citizens during the hurricane season.
Mission #2: Ready the Nation for Catastrophic Disasters
We are in a catastrophic disaster for which we are not ready. And we are in a hurricane season for which we are not ready.
When communities open shelters, volunteer groups fetch trucks and trailers from a lot and drive them to a community structure. These volunteers tend to fit basic demographics – they tend to be older and likely retired. They are people who have flexibility in life and schedule to drop other tasks to get training and open a shelter. New York City does an interesting thing with paid NYC employees. I think that is unusual.
There is a significant overlap between the COVID-19 vulnerable population and anticipated shelter staff.
We should probably be recruiting, training, and preparing sheltering staff? And maybe recruiting from a demographic that is less vulnerable.
The predominant guidance from FEMA for 2020 hurricane involves shelter-in-place – which means stay home.
So maybe, there is guidance we need for that? How to people get food, water, power, medications, and such on day three after a hurricane? Do we really shelter-in-place, then get flooded and rescued by Coast Guard Helicopters and the Cajun Navy? Again, let’s recognize this is not a plan.
FEMA “Proper Emergency Kit Essential to Hurricane Preparedness” dates to August 20 of 2018. Happily it is tagged “release NR-026. I wonder what NR-027 might look like? Would the list change for 2020?
FEMA Shelters & Homeless Shelters
Let’s look at homeless shelters as a clue of what may lay ahead for us.
The traditional structure of homeless shelters tends to expose people to COVID-19. Nearly 20% of New York Hotels are being used to house 13,000 homeless people for more than $2M per night. The mayor of New York plans to ask FEMA for reimbursement as part of the COVID response effort.
In Boston, the City put homeless folk into university dorms. A Best Western Hotel is also in the mix for this effort. At one point, a third of the homeless folks staying at the Pine Street Inn (a shelter) tested positive for COVID.
It appears that putting displaced people into hotels maybe a thing that happens. Is there a plan in place? Are there contracts in place? Are we staffed for that? Do we have cost accounting practices in place? Do we have monitoring for health and safety in place? Is there an actual plan?
The Closing
I’ll close with this entirely true story:
FEMA occasionally puts people in hotel rooms following disasters. It is called Transitional Sheltering Program (Sadly called TSA – which is not to be confused with the Transportation Security Agency). I’ll say: Hotel Program instead of TSA.. fair enough?
OIG Report 20-58, published 05 Aug 2020 (last week!)
FEMA released personal information related to 2.3 million disaster survivors who participated in the Hotel Program, increasing the risk to these Americans for subsequent identity theft.
- Inadequate oversight may have increased the risk that unacceptable lodging conditions were met
- There were procurement failures and contract failures.
- FEMA spent more than $642 million for more than 5 million hotel rooms.
- FEMA did not take corrective action to address identified failure as they were happening.
- FEMA staff and contractors did not have the required or appropriate training.
Restatement
Failed Planning
Failed Procurement
Failed Contract management
Failed Training
Impact
$642M spent for conditions that may have been substandard
Data breach - 2.3 million American's have personal data in the hands of thieves and crooks
Helluva Job FEMA!
I think the Failures from 2005 and Hurricane Katrina are still failures. What do you think?
Mission #3: Reduce the complexity of FEMA.
Let’s do 1 and 2 first, huh?