Comment Submitted by Peter Sala, New York City Police Department

Document ID: FEMA-2011-0018-0016
Document Type: Public Submission
Agency: Federal Emergency Management Agency
Received Date: October 14 2011, at 12:00 AM Eastern Daylight Time
Date Posted: October 17 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: October 4 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: November 3 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f52b9b
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I read and evaluated the All Hazards Planning Section Chief PTB, FEMA-2011-0018-0007, and compared it to a prior version. I appreciate the effort that went into making the guide, even if only making a few slight reference changes, into one with a general hazard focus. Clearly the guide has functioned well for a while and as such few substantive changes were included. The augmentation of the Responsibilities section starting on page 3, line 34 was useful in cross referencing these to appropriate officials in my agency. As for issues I have with the draft, I found it difficult to reference a task and associate it to a behavior because the behaviors in this draft were not numbered. I suggest that the competencies and behaviors be numbered or lettered, and the tasks numbered accordingly to allow for more exact reference (as in the previous edition). Page 9, line 44 appears to implement a new behavior. I question whether the behavior and task are not better suited to Command (“establish an organizational structure”) or even Operations functions of organizing resources to meet tactical objectives. Regarding the coding of the tasks, I am concerned that of the 71 tasks only 6 are listed as O. Is it really the case that only 8% of all the listed tasks can be measured and evaluated on other than an actual incident? It still seems very restrictive. In my opinion a well prepared, large scale (read: expensive) exercise could be a valuable place to measure some of these behaviors and tasks. There are very practical matters which make it difficult to participate and evaluate on large scale incidents. I hope this discussion could be revisited. Finally I noticed two grammatical problems: • Page 11, Task 34 - The word “continuously” should read “continually” (sorry, I’m a grammar buff) • Page 13, task 50 – refers to the Finance Section “Leader” which was probably just a typo, but should be changed to the appropriate position title that you wish to reference

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