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National Advisory Council 
January 28, 2011 

MEMORANDUM TO: 	W. Craig Fugate Administrator, FEMA 
FROM: James G. Featherstone, Chairman, National Advisory Council
SUBJECT: National Advisory Council National Exercise Program Implementation Recommendations Report 
The purpose of this memo is to transmit the recommendations of the National Advisory Council to the FEMA Administrator for his consideration as FEMA moves forward with the implementation of the revised National Exercise Program. In response to the questions put before the AC the Council recommends the following: 
1. What priority issues do you think should inform objectives for the initial 2-year NEP series? How can the program be designed to ensure it incorporates the whole of community in accordance with the FEMA Administrator's priority? 
• Council members encourage the program and objectives to be based on realistic objectives and to stay away from scripted events. It is believed that including local, tribal and state partners in the planning phase might provide for more realistic concerns. It is also believed that emphasis should be placed on exercising specific objectives rather than scenarios. 

• Council members support a NEP that has each exercise building upon lessons learned and objectives tested in previous exercises. Members caution that the focus should be first on increasing the breadth of the program, not both breadth and depth simultaneously. 

• Members were overwhelming in their belief that the NEP needs to be inclusive of the whole of community to include government at all levels, non-government organizations, faith-based organizations, and the private sector to the greatest extent possible. This broad-reaching participation adds to the realism of the event. 


2. How would you suggest FEMA gain better visibility on existing exercises across the enterprise? What criteria and selection process should be used to determine whether exercises are incorporated in a 2-year EP series? 
• Council members believe that FEMA can enhance their involvement and visibility through the greater use of FEMA regional staff engaging with tribal, local and state stakeholders. FEMA should participate at all levels, this added presence will lend itself to increased visibility on the part of FEMA. The criteria and selection process for determining the incorporation of exercises in a 2-year NEP series should emphasis exercising specific objectives with a focus on increasing the breadth of the program first and not both breadth and depth simultaneously. 
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3. How should no-notice and limited-notice exercises be incorporated in the NEP, and what are the pros and cons of this approach? What effect will the new NEP have on state, local and tribal, nongovernmental organizations, their exercise programs, and private sector resources and personnel requirements? 
• Generally speaking, members were in favor of no-notice and limited notice exercises provided that caution is used to avoid embarrassment of elected officials who may be less engaged in the day-to-day planning of emergency management. It was suggested that FEMA might notify several jurisdictions of their “possible” inclusion in an event, and then actually utilize only a small percentage of those. This advance notice could be directed to the senior most level to include elected officials.  
4. How can we improve the evaluation and after action reporting from exercises to ensure rapid knowledge sharing and better follow-through corrective actions? What strategies would the NAC recommend for ongoing stakeholder collaboration upon approval of the NEP plan by the Secretary of the Department of Homeland Security? 
• Members expressed concern that in the last several years, exercises and their evaluations have become “cookie cutter” in nature. It is recommended that these reviews provide honest and accurate feedback to the entities involved on areas for improvement. 
• Members also believe it is essential that follow-up to the after action reports occur in a timely and consistent fashion; and that verification of improvements identified in the exercise be assessed. 


Introduction 
The National Exercise Program was established in 2007 to provide a framework for prioritizing 
and coordinating Federal, Regional and State exercise activities, without replacing any individual 
department or agency exercises.1 The NEP has helped prepare and train government officials, 
reinforced identified training standards, and systematically tested the national preparedness 
system. Moreover, the NEP has served as a catalyst for enhancing collaborative relationships, 
validating plans, and identifying areas for corrective action. In short, it has served as a key 
component of our national readiness to confront all hazards. 

Under Title 6, United States Codes, Section 318, the National Advisory Council (NAC) is 
directed to advise the Administrator of the Federal Emergency Management Agency on all 
aspects of emergency management. Additionally, Section 748 specifically directs the 
Administrator to coordinate with the National Advisory Council in carrying out the National 
Exercise Program (NEP). This issue paper will provide an update to the members of the Council 
on the current initiative to reform and improve the National Exercise 
Program and serve to solicit initial input and recommendations. 

In August the Secretary of Homeland Security directed the Administrator to initiate a 90-day 
effort to revise and improve the NEP. The Secretary’s mandate calls for building upon existing 
aspects of the program, but adopting a progressive structure that incorporates the principles of 
realism, agility, and collaboration. The revised NEP must better serve its stakeholders and 
provide an effective mechanism to prepare and test the entire homeland security enterprise 
against common objectives that reflect national priorities. 

FEMA’s National Exercise Division (FEMA/NED) led this revision effort. A revised 
National Exercise Program was delivered to the Secretary on November 15, 
2010. 

The following concepts are currently under consideration for incorporation into the revised 
National Exercise Program: 

• Scope: The NEP will encompass a series of exercises of all types (i.e., drills, tabletops, modeling and simulation, no-notice/limited notice events, functional, full-scale, etc.) for participants at all levels (i.e., Federal, State, local, tribal, territorial, private sector) to be conducted over the course of a two-year cycle. 

• Progressive: Each two-year cycle will actively engage and involve the participation of multiple stakeholders across the entire homeland security enterprise, feature an increasing level of complexity over time, and will be anchored to a set of common objectives. 

• Objectives: The NEP will be an objectives-driven program, with the Primary Objectives of each two-year cycle being set by the Secretary, the FEMA Administrator, and the Assistant to the President for Homeland Security and Counterterrorism. The NEP will 


http://www.fema.gov/emergency/nrf/nationalexerciseprogram.htm 
leverage existing exercises that are consistent with the objectives determined by 
leadership. 
• Collaborative: The NEP will actively incorporate Federal, State, local, tribal, and territorial partners and private sector stakeholders in the planning, conduct, and evaluation of each two-year cycle. Where appropriate, the planning process will be shortened to accommodate a larger volume of exercises. 

• Realism: Each two-year cycle will feature an increased number of no-notice/limited notice exercises, with exercise play driven more by player actions than scripted injects, where possible. 

• Readiness: All NEP exercises will reflect current risk assessments. 

• Capstone: Each NEP two-year cycle will culminate in a comprehensive, full-scale, intergovernmental exercise that will address the Primary Objectives of the given cycle. 

• Evaluation: The evaluation of NEP exercises will focus on the rapid, agile development of corrective actions and lessons learned that can both quickly improve the performance of exercise participants and inform broader assessments of national preparedness. The NEP implementation plan is being drafted by FEMA/NED. As part of our outreach program, FEMA/NED would like to provide an overview briefing to the NAC on steps taken to this point and to solicit input and ideas for the revised NEP. The NAC’s insights will prove extremely valuable to the NEP writing team. 


FEMA specifically asked the Council to consider providing thoughts on the following issues:2 
• What priority issues do you think should inform objectives for the initial 2-year NEP series? How can the program be designed to ensure it incorporates the whole of community in accordance with the FEMA Administrator’s priority? 

• How would you suggest FEMA gain better visibility on existing exercises across the enterprise? What criteria and selection process should be used to determine whether exercises are incorporated in a 2-year NEP series? 

• How should no-notice and limited-notice exercises be incorporated in the NEP, and what are the pros and cons of this approach? What effect will the new NEP have on State, local, tribal, nongovernmental organizations, their exercise programs, and private sector resources and personnel requirements? 

• How can we improve the evaluation and after action reporting from exercises to ensure rapid knowledge sharing and better follow-through corrective actions? What strategies would the NAC recommend for ongoing stakeholder collaboration upon approval of the NEP plan by the Secretary of the Department of Homeland Security? 


Revision and Realignment of the National Exercise Program Issue Paper for the NAC. (October 2010) 

NAC Responses to Questions 
The Council received a briefing on and examined FEMA’s efforts to revise the National Exercise Program during a public teleconference on November 10, 2010. Based on the briefing and the draft recommendations proposed by the NAC’s Preparedness & Protection Subcommittee, the Council put forward initial recommendations on the NEP revision (Appendix A) and planned to provide additional recommendation and feedback based on the questions posed in the NEP issue paper to inform the development of the NEP Implementation Plan. 
Through Subcommittee discussions following the November 10th teleconference around the four questions raised by FEMA, the Council focused on the following topics. 
1. After Action Report and Lessons Learned Terminology: Members expressed concern that in last several years exercises seemed to become cookie cutter exercises without an honest after action report.  In the past some items have not been included in After Action Reports because of potential liability concerns regarding the impact of delays in implementing a corrective action. An adjustment of the language would allow officials to have the opportunity to make changes and get feedback without unnecessary exposure to litigation. For example, referring to suggested improvements rather than corrective actions. Some local levels also no longer use the term standard operating procedures and instead use suggested operating guidelines. The overall terminology shift that needs to be made is to focus on areas for improvement instead of things not properly executed. 

2. Follow-Up after an Exercise: As officials shift the terminology used in After Action Reports there is a concurrent need for additional follow-up through meetings, training, and exercises to determine whether issues raised in the After Action Report have been addressed to come full cycle.  This focus on accountability will strengthen the view of After Action Reports as a tool to make progress in a community’s readiness. 


It is important to include the necessary follow up after the actual exercise is over as part of the definition of an “exercise”. This way whether it is a full field exercise, a table top, or a limited notice drill there will be the commonality of the AAR and also a follow-up look at steps taken on items identified in the AAR. It may not be realistic to mandate full corrective action or perfect resolution but as part of the exercise we must include the time, staff, and funding necessary to ensure that lessons taken away from an exercise become lessons learned and implemented. 
There needs to be a system in place that tests if the issues discovered in the after action have been resolved, perhaps by a 90-day progress report.  The tracking system should balance accountability for what is being tracked. Something similar to NIMSCAST that has quick action reports and when doing the NIMSCAST assessment you’ll get notification and reminder. However, if localities and states don’t have resources to make the changes, FEMA should not penalize them. 
3. Realism: Council members like the emphasis on keeping things realistic and moving away from scripts, such as in table tops.  For example, shutting down IT in the command center; demonstrating how things could really happen forces people to stress a little bit.  The realism of an exercise is often conceptualized by the federal government but best defined by local communities on the ground including need for a broader array of competency exercises. The realism will also be further supported by the new emphasis on exercising objectives rather than scenarios. 

4. Gradually Building: Appreciate the progressive aspect of the exercises increasing in complexity, scale and intensity. However, another priority may be limiting the scope for the first year. Council members caution that the focus should first be on increasing the breadth, not both breadth and depth.  Don’t bite off too much at one time. Also, when dealing with exercise for elected or appointed officials, exercises should gradually build on their past experience to an unannounced full-scale exercise so that we don’t set people up to fail.  Everyone should know what his or her role is, otherwise there is non-participation.  Although if we make it too straight forward, it won’t be real and test stress.  As a part of expanding breadth, the Council would like to see the integration of various funding silos and exercises, such as pods or bio watches.  In the past, exercises have not been related, are resource intensive and not efficient which underscores the need to make these exercises less abstract and more realistic. 

5. Inclusiveness: Members suggested that every exercise should have a community of effort component to look at shared resources and recovery in the long term. Part of an exercise should test capability of government by engaging all levels of government—the unity of effort goes across the spectrum and need to include diversity of scale in terms of city size, state size, local and tribal. This would also necessitate further examination of the forms of government involved.  The private sector must also be involved in all stages to have an inclusive exercise. The private sector is well organized in individual sectors at the national level and they will respond.  However, as exercises move from Washington to the regions, there is less organization and more reliance on individual’s knowledge and contacts.  FEMA should reach out to its federal partners and develop the infrastructure to identify the right people in a particular locality.  

6. Visibility: Visibility means who across the enterprise and the community is aware of what is going on. The NEP is written from a Federal perspective of what they will do, which makes better visibility with partners a vital component for success.  Also, encouraging more players to participate in the exercise will increase visibility. The same players always seem to be at exercises, but those not used to exercises, such as other Federal partners, should be invited to participate for comprehensive participation.  

FEMA can enhance their involvement and awareness of exercises through greater use of FEMA regional staff in engaging with tribal, locals and state personnel. FEMA should participate in local drills and the exercise should be designed around FEMA’s participation.  This would increase the visibility of exercises through increased FEMA presence.  

7. Limited Notice Exercises: The Council discussion focused on thinking of exercise in terms of building blocks—the local level exercise should build up to a larger all-encompassing exercise.  Both no-notice and limited-notice exercises should engage the local level. No-notice exercises are excellent learning opportunities if one approaches it with the mindset that the purpose of the exercise is to test capabilities without much preparation.  An example of a false alarm disaster of a commercial jet liner going down in Tampa Bay was discussed.  Those situations can provide important lessons that no-notice exercises can use. 


Members agreed that no-notice and limited-notice exercises should be part of the NEP for States and locals, but expressed logistical concerns related to elected officials.  To address this several local officials should be initially notified that they may be participating in an exercise, but only a few will be selected to actually participate.  The preparation would ensure that the local officials, especially those newly elected, are comfortable in their roles and responsibilities for the exercise. This preparation would support the NEP concept of progressive exercise schedule. 
If there was an indication that one’s county might be notified in the next week about participating in an upcoming exercise, one would likely notify the appropriate backups or may cancel vacation plans.  In reality when disaster strikes, some senior people may be away and the people at lower levels fill in the gaps.  A no-notice drill really tests if the backups can handle the incident. A good exercise will test an organization’s ability to respond in unusual circumstances, which might be having the senior people out.  Part of the scenario should be that all senior leadership is away at a conference and unable to assist in the exercise.  

NAC Recommendations 
After much discussion and deliberation the NAC would like to provide the following recommendations to Administrator Fugate for his consideration as FEMA moves forward with the implementation of the revised National Exercise Program. In response to the questions put before the NAC the Council recommends the following: 
1. What priority issues do you think should inform objectives for the initial 2-year NEP series? How can the program be designed to ensure it incorporates the whole of community in accordance with the FEMA Administrator’s priority? 
• Council members encourage the program and objectives to be based on realistic objectives and to stay away from scripted events. It is believed that including local, tribal and state partners in the planning phase might provide for more realistic concerns. It is also believed that emphasis should be placed on exercising specific objectives rather than scenarios. 

• Council members support a NEP that has each exercise building upon lessons learned and objectives tested in previous exercises. Members caution that the focus should be first on increasing the breadth of the program, not both breadth and depth simultaneously. 

• Members were overwhelming in their belief that the NEP needs to be inclusive of the whole of community to include government at all levels, non-government organizations, faith-based organizations, and the private sector to the greatest extent possible. This broad-reaching participation adds to the realism of the event. 


2. How would you suggest FEMA gain better visibility on existing exercises across the enterprise? What criteria and selection process should be used to determine whether exercises are incorporated in a 2-year NEP series? 
• Council members believe that FEMA can enhance their involvement and visibility through the greater use of FEMA regional staff engaging with tribal, local and state stakeholders. FEMA should participate at all levels, this added presence will lend itself to increased visibility on the part of FEMA.  The criteria and selection process for determining the incorporation of exercises in a 2-year NEP series should emphasis exercising specific objectives with a focus on increasing the breadth of the program first and not both breadth and depth simultaneously. 
3. How should no-notice and limited-notice exercises be incorporated in the NEP, and what are the pros and cons of this approach? What effect will the new NEP have on state, local and tribal, nongovernmental organizations, their exercise programs, and private sector resources and personnel requirements? 
• Generally speaking, members were in favor of no-notice and limited notice exercises provided that caution is used to avoid embarrassment of elected officials who may be less engaged in the day-to-day planning of emergency management. It was suggested that FEMA might notify several jurisdictions of their “possible” inclusion in an event, and then actually utilize only a small percentage of those. This advance notice could be directed to the senior most level to include elected officials.  
4. How can we improve the evaluation and after action reporting from exercises to ensure rapid knowledge sharing and better follow-through corrective actions? What strategies would the NAC recommend for ongoing stakeholder collaboration upon approval of the NEP plan by the Secretary of the Department of Homeland Security? 
• Members expressed concern that in the last several years, exercises and their evaluations have become “cookie cutter” in nature. It is recommended that these reviews provide honest and accurate feedback to the entities involved on areas for improvement. 

• Members also believe it is essential that follow-up to the after action reports occur in a timely and consistent fashion; and that verification of improvements identified in the exercise be assessed. 


Conclusion 
The Council has completed its review of the implementation of the National Exercise Program (NEP) utilizing the questions posed to the NAC by FEMA. It is the conclusion of the Council that the agrees with the overall focus and direction of the revision to the NEP, but as highlighted in the Council’s discussion there will be many challenges to an implementation that will maximized the exercise program’s effectiveness and efficiency.  

Appendix 
A. November 10, 2010 NAC Public Teleconference Minutes 
B. November 10, 2010 NAC Memo on the Revision of the National Exercise Program