Running head: GROTON EMERGENCY RESPONSE CRITIQUE 1

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GROTON EMERGENCY RESPONSE CRITIQUE 2

Groton Emergency Response Critique

Keith Reynolds

University of Phoenix

CJA 560

Ian Moffett

August 23, 2010

 Groton Emergency Response Critique

Eastern Connecticut’s [Apostrophe: remove if the word is not possessive] Town of

Groton sits in between the Mystic and Thames Rivers on Fishers Island Sound, which opens up

into the Long Island Sound. It has lush green woods and rugged hills sloping down upon rocky

shores and sandy beaches. The area was first charted [The passive voice is a form of "be"

(was) and a participle (charted ). Over-use of the passive voice can make paragraphs

officious and tedious to read. Try to use the active voice most often; for example, passive

voice = The paper was completed on time. Active voice = the student completed the paper

on time--See eCampus > Center for Writing Excellence > Tutorials & Guides > Grammar

& Writing Guides > Active & passive voice] by the Dutch explorer Adrian Block in 1614 and

settled in 1637 when Captain John Mason forced the Pequot Indians to retreat from their Mystic

fort. Today Groton is a regional hub of commerce and industry and tourism. Several significant

facilities to note in the immediate vicinity of Groton are the U.S. Naval Submarine Base, Electric

Boat Division of General Dynamics, Pfizer Inc. [Doctoral-level comment (but recommended

for any collegiate writer)--Write out abbreviations in academic essays] and at the Groton-

New London Airport, in addition to the nearby Millstone Nuclear Power Station. The area has

interstate highway access and passenger train service. The weather is temperate, but hurricanes

and [Check punctuation: insert a comma before this word if this is the last in a list of more

than two -- or if it begins a new clause] tornados are not unheard of. A modern and beautiful

place to live and work, Groton also has established a professional and volunteer emergency

response plan as part of national and state-wide incident management efforts after the lessons of

9-11 [Write out numbers under 10] and Katrina.

In Connecticut, the state General Statutes declares:

 “No town or city of the state shall be eligible for any state or federal benefits under this

chapter until such town or city has submitted to the commissioner an emergency plan of

operations approved by the local director of civil preparedness and the local chief

executive which is subsequently approved by the commissioner” (Department of

Emergency Management and Homeland Security, 2005, p. 1).

under Chapter 517 (Civil Preparedness. Department of Emergency Management and

Homeland Security) Section 28-7 (Local and joint organizations).

The Connecticut Office of Emergency Management (OEM) offers municipalities

planning guides to assist local officials with developing and updating their local emergency

response plans. The planning guides are generally based [Passive voice] on the Federal

Emergency Management Agency’s (FEMA) Guide For All-Hazard Emergency Operations

Planning, SLG-101. The OEM notes that:

“Local officials may use the FEMA Guide SLG 101 or the State OEM guides (we think

the OEM guides are more user-friendly). However, all local plans should contain annexes

for Situation Reporting and Preliminary Damage Assessment developed in conformance

with the State OEM guides (FEMA Guide SLG 101 does not contain model annexes for

Situation Reporting or Preliminary Damage Assessment)” (Department of Emergency

Management and Homeland Security [DEMHS], 2010, p. 1).

The Town of Groton The Town’s Emergency Operations Plan (EOP) has been available

online since September 12, 2007 (Town of Groton, Connecticut, 2004, p. 1). The stated purpose

of the EOP is in Appendix I of this paper.

The purpose of this paper is to review and critique the Groton’s EOP using FEMA’s

Continuity of Operations (COOP) Self-Assessment Tool and related materials as a lens to

evaluate the quality and efficacy of the plan. Secondarily the paper will identify [Doctoral-level

comment (but recommended for any collegiate writer)--Avoid anthropomorphisms

(attributing human characteristics to nonhuman or inanimate objects). Consider that no

paper can "identify." Try something like "In this paper I will identify. . ."] how the COOP

model might [Check word usage: Use "might" to indicate an uncertain possibility. Use

"may" for a possibility almost a sure thing] provide improvements to the plan in the future

[Redundancy: "in the future" is repetitive--"will identify" means in the future] .

SWOT – Problem Solving [If these two words function as an adjective, they should be

spelled as a single hyphenated word] Model

Strengths

1) The Town of Groton has an Office of Emergency Management; 2) Facilities such as

the Navel Base and General Dynamics, Millstone Nuclear Power Station have contributed to a
culture of safety planning and emergency responses.

Weaknesses

1) Budgets are tight, 2) no civilian hospital in the town.

Opportunities

1) Federal grants, 2) regional training exercises.

Threats

This is the list of hazards the Town of Groton specifically references in the EOP:

“The Town of Groton is vulnerable to any and all types of disasters including hurricanes,

tornadoes, severe windstorms, blizzards, electrical storms and flooding. Earthquakes,

forest and brush fires are also a possibility. Chemical, transportation and radiological

accidents as well as major structural fires, public demonstrations and civil disturbances

and enemy attack all must be seriously considered as potential disaster possibilities. In a
 nuclear attack, even if not the recipient of a direct hit, prevailing winds would make it

necessary for the population to seek and use all available protection from radioactive

fallout. The location of an airport in the town suggests the further possibility of air

crashes within town boundaries” (Town of Groton, Connecticut, 2004, p. 9).

Response Phase

The EOP developed by the Town of Groton was created [Passive voice] using the State

OEM template. The four phases of a critical incident under the state definition in the template

are: Mitigation, Increased Readiness, Emergency and [Check punctuation: insert a comma

before this word if this is the last in a list of more than two -- or if it begins a new clause]

Recovery. These four phases are referred [Passive voice] to collectively as [Doctoral rule (but

good advice for any academic writer)--avoid a split infinitive; consider placing the adverb

(collectively) before or after the infinitive (to as )--try "collectively to as " or "to as

collectively" (or place "collectively" later in the sentence)] the Concept of Operations in

Groton’s EOP. Similar to the Response Phase as outlined in FEMA’s definition of a critical

incident provided under the National Incident Management System (NIMS), Connecticut’s

Emergency Phase is analogous to the federally defined Response phase. The Town of Groton

defines the Emergency Phase as:

“The Emergency Phase is that period of time during which the emergency is occurring.

Action will be taken immediately to evaluate the emergency, warn the population, make

use of all available personnel, equipment and resources to minimize the effects of the

disaster on the community” (Town of Groton, Connecticut, 2004, p. 1).

According to the Town of Groton’s EOP document, a State [Do not capitalize this

word] if Emergency/Disaster must be declared [Passive voice] in writing by the Town Manager
[A job title is not capitalized unless it is the first word in a sentence or associated with the

name of a person or institution, e.g., Certified Public Accountant John Doe. If not, it is just

a label, such as auto mechanic, nuclear physicist, fry cook, brain surgeon, professor, etc.]

with consultation from the Director of Emergency Management. The following circumstances

and conditions need to be present in order to [Clear writing suggestion--the meaning will be

the same (and less wordy) by removing "in order"] declare a State of Emergency/Disaster:

“1) The situation has created a clear and present threat to life and/or property, and, 2.)

The resources available to the Town Manager locally (i.e. within the Town) have been

exhausted, or the Chief Executive determines that, based on existing conditions, such

resources are likely to be exhausted before the threat to life or property passes” (Town of

Groton, Connecticut, 2004, p. 1).

Overview of COOP

Continuity of operations planning (COOP) is the process to put in place a structure,

resources and guidelines to ensure government can continue essential functions in the event of a

natural or manmade disaster. The goal is to restore operational support for citizens, personnel,

partners and other constituents should the emergency cause the loss of facilities, essential records

or [Check punctuation: insert a comma before this word if this is the last in a list of more

than two -- or if it begins a new clause] computing assets.

The COOP methodology [Check spelling: "Methodology" is the study of methods. A

"method" is a process or technique ] requires that government officials define essential

functions and prepare alternatives to continue the tasks personnel must perform them regardless

of circumstances. Examples of essential functions include fire, law enforcement, health care,

border patrol, communications, financial operations and [Check punctuation: insert a comma
before this word if this is the last in a list of more than two -- or if it begins a new clause]

environmental containment (DePompa, 2010, p. 1).

FEMA’s Continuity of Operations Self-Assessment Tool is a framework for officials to

evaluate their organization’s plan and ability to deliver essential services. The Self-Assessment

Tool is part of a set of materials designed to help governmental organizations become Federal

Preparedness Circular 65 (FPC 65) compliant. FPC 65 provides guidance to “Federal Executive

Branch departments and agencies for use in developing contingency plans and programs for

COOP” (Federal Emergency Management Agency [FEMA], 2006, p. 1).

The Self-Assessment Tool provides a color-coded matrix to evaluate 12 areas as Fully

Addressed (Green), Partially Addressed (Yellow), or Not [Punctuation: remove the comma if

the following is not an independent clause (could not be a sentence by itself) OR is not the

last element in a series of more than two] Addressed (Red) under FPC 65 guidance. The 12

areas are: Plans and Procedures, Identification of Essential Functions,

Delegations of Authority, Orders of Succession, Alternate Operating Facilities,

Interoperable Communications, Vital Files, Records and Databases, Human Capital [Unless

starting a sentence, do not capitalize this word ] , Tests, Training, and Exercises, Devolution

of Control and Direction, Reconstitution Operations, Agency Head Responsibilities (Federal

Emergency Management Agency [FEMA], 2010.

Critique

This section provides a critique of the Town of Groton regarding some of the criteria

outlined under the COOP Self-Assessment Tool. In general, the EOP developed by the Town of

Groton is very light on detail. There is ["There is" is an awkward phrase if "there" is not

clearly a location] however ["However" in this case is a parenthetical word--a sort of "by
the way"--and it should be surrounded by commas] an index of Annexes supplied in the

Appendix, which seem to indicate there is additional detail on some of the COOP topics,

including both Direction/Control and Communications. The plan clearly defines that “tasked

organizations,” including those Groton departments identified in the EOP, and all other

government or private sector organizations that have been assigned tasking in the Emergency

Operations Plan are to develop their own detailed plans to perform their response functions.

Plans and Procedures

The plans and procedures component of this document is contained [Passive voice] in

the Concept of Operations section. There is [Avoid using this phrase] little detail, but it does

spell out how to declare an emergency and under what circumstances. The procedures to

operationalize the emergency, or response phase are defined [Passive voice] as: “1) Immediately

alert the public affected. Provide them with whatever guidance or instruction is required to

respond to the emergency, 2) Activate this Emergency Operations Plan, 3) Fully activate the

Emergency Operations Center on a round-the-clock basis. Take appropriate steps for water, food

and sleeping facilities if the emergency requires it, 4) Declare "State of Emergency" if

appropriate and necessary, 5) Establish communications with the State Emergency Management

Area Office, cities and towns with which mutual aid agreements are in effect, 6) Conduct

emergency operations in the most efficient and expeditious manner possible using all available

manpower, equipment, fallout protection and other resources.”

The Groton EOP is to be reviewed [Passive voice] annually in line with COOP

standards.

Identification of Essential Functions

 The plan does identify that all tasked organizations must protect “records, facilities, and

organizational equipment deemed essential for sustaining government functions and conducting

emergency operations” (Town of Groton, Connecticut, 2004, p. 19).

Delegations of Authority

Delegation of authority is an area of focus for the Town of Groton’s EOP. The purpose is

to outline who is responsible, not how they will respond. This plan states that the emergency

functions for groups providing emergency management will parallel normal day-to-day functions

and the same personnel and material resources will be used to the extent possible.

Orders of Succession

This is clearly spelled [Passive voice] out for the senior town officials. In order to

[Clear writing suggestion--the meaning will be the same (and less wordy) by removing "in

order"] provide local government continuity of operations during an emergency “resulting from

a disaster (natural, human caused or national security), the following line of succession shall

prevail: a. Town Manager, b. Chief of Police c. Director of Public Works” (Town of Groton,

Connecticut, 2004, p. 23).

Alternate Operating Facilities

Each department in the Town of Groton is to “ensure, if practical, that alternate operating

locations are available should the primary location suffer damage, become inaccessible, or

require evacuation. Alternative operating locations provide a means to continue organizational

functions during emergency conditions” (Town of Groton, Connecticut, 2004, p. 19).

Interoperable Communications

There is [Avoid using this phrase] a focus on the communication between the town and

the State [Remove capitalization if this is not a complete name (a proper noun)] [Do not
capitalize this word] and/or [Do not use "and/or"] Federal Emergency Operations Centers

(EOC). In the discussion of Phase Two, the Increased Readiness Phase, the Groton EOP states

that, “the Emergency Management Director will coordinate the inspection of all communications

and auxiliary generating equipment to ensure its operating capability” (Town of Groton,

Connecticut, 2004, p. 11).

Vital Files, Records and Databases

The Groton EOP identifies that all departments and agencies have certain common tasks,

which include making provisions for the protection of all “vital departmental records” (Town of

Groton, Connecticut, 2004, p. 18).

Human Capital [Unless starting a sentence, do not capitalize this word ]

The Groton EOP does not address the scope of the Human Capital [Unless starting a

sentence, do not capitalize this word ] criteria as outlined in the COOP Self-Assessment Tool

Tests, Training, and Exercises

One of the stated purposes of the Groton EOP is to provide a foundation for “preparation

of detailed emergency operating procedures and training by local government and support

organizations assigned emergency responsibilities” (Town of Groton, Connecticut, 2004, p. 6).

Additionally, the role of the Emergency Management Director [Do not capitalize job names] is

specifically defined, [Passive voice] referencing the oversight of training and practice as one of

his main duties.

Devolution of Control and Direction

Devolution planning for the process to shift statutory authority for essential functions

from the Town of Groton to State [Remove capitalization if this is not a complete name (a

proper noun)] [Do not capitalize this word] or Federal authorities in order to [Clear writing
suggestion--the meaning will be the same (and less wordy) by removing "in order"] sustain

operations capabilities for an extended periods is not addressed in the EOP.

Reconstitution Operations

The EOP does spend a significant portion of effort on the Recovery Phase of its Concept

of Operations.

Agency Head Responsibilities

The EOP clearly addresses the roles and responsibilities of all of the people and

organizations involved with incident management before, during and [Check punctuation:

insert a comma before this word if this is the last in a list of more than two -- or if it begins

a new clause] after an emergency. The management of the emergency response is broken into

four groups: Policy, Control and Coordination, Direction and Supervision and [Check

punctuation: insert a comma before this word if this is the last in a list of more than two --

or if it begins a new clause] Field Units. The Policy group is made up of senior officials who

create the emergency policies and, “in specific emergency situations will discuss the economic,

political, legal, and social implications of both the threat and the response to determine the best

general approach to the situation. All major policy decisions are made by this group” (Town of

Groton, Connecticut, 2004, p. 24).

Solutions from Related Readings and Standards

Two clear elements that could add to Groton’s EOP are the COOP Self-Assessment Tool

Human Capital [Unless starting a sentence, do not capitalize this word ] and Devolution.

Human Capital [Unless starting a sentence, do not capitalize this word ] emphasis would

increase the focus on improving the collective skills, knowledge and expertise of people involved

with emergency management to improve results. Devolution would insure [Use "ensure"
unless this refers to an insurance policy] MOUs are in place for the smooth transition in the

unlikely even that the Town could not participate in a Unified Command (UC). An example of

the latter was when the Governor of Louisiana would not give Federal authorities authorization

to nationalize the National Guard for fear that they would no longer be authorized to enforce

state laws.

The Town of Groton’s EOP is a living document that outlines the municipalities response

to critical incidents of all kinds. It is the guiding document that organizes and directs people to

save lives and protect property by ensuring emergency operational capabilities exist to mitigate,

prepare, respond, and recover in the face of any emergencies or disasters. Tools like the Self-

Assessment can provide a means for Groton to constantly improve [split infinitive] the ability

to meet this important goal.

 References

DePompa, B. (2010). COOP Basics: How to Ramp up Preparedness Now. Retrieved August 22,

2010, from http://gcn.com/microsites/2010/coop/ramp-up-preparedness.aspx

Department of Emergency Management and Homeland Security. (2005). Chapter 517 Civil

Preparedness (). Washington, DC: U.S. Government Printing Office.

Department of Emergency Management and Homeland Security. (2010). Model Local

Emergency Operations Plan. Retrieved August 22, 2010, from

http://www.ct.gov/demhs/cwp/view.asp?A=1928&Q=287950

Federal Emergency Management Agency. (2006). Continuity of Operations (COOP) Pandemic

Influenza Guidance. Retrieved from

http://www.fema.gov/txt/government/coop/coop_influenza.txt

Federal Emergency Management Agency. (2010). Continuity Of Operations Self-Assessment

Tool. Retrieved August 22, 2010, from

http://www.fema.gov/government/coop/coopassessment3.shtm

Town of Groton, Connecticut. (2004). Town of Groton, Connecticut Emergency Operations Plan

and Annexes. Retrieved August 22, 2010, from

http://www.town.groton.ct.us/depts/adminsvcs/docs/BasicEmergencyOperationPlan.pdf
 APPENDIX I

The purpose of this Emergency Operations Plan is to;

A. Maximize survival of people, prevent and/or minimize injuries and preserve property and

resources in the Town of Groton by making use of all available manpower, equipment

and other resources in the event of emergency/disaster.

B. Provide for direction, control and the continuity of government in disaster situations. C.

Provide for the integration of resources and capabilities of local government and private

sector agencies for hazard mitigation, survival and recovery operations when any disaster

threatens or occurs.

D. Define the role and responsibilities of local government, quasi-government organizations and

private agencies for the preparation and conduct of emergency operations prior to, during

or after a disaster.

E. Provide a basis for the preparation of detailed emergency operating procedures and training by

local government and support organizations assigned emergency responsibilities.

(Town of Groton, Connecticut, 2004, p. 6)