2.6. Illustrative Planning and Decision Process for Chemical Incident Consequence Management

An effective approach to chemical incident consequence management encompasses multiple key elements—involving Whole Community partners, stakeholders, and technical expertise;²² accurately understanding the hazard(s) involved and its impacts on people, infrastructure, and the environment effects; developing and implementing appropriate remediation strategies based on carefully considered course of action (COA) analysis; and determining and documenting how resources will be applied during the incident characterization, remediation, and site clearance processes.

This section describes a generic planning and decision process that FSLTT Whole Community response and recovery leadership can use to achieve the desired end-states for chemical incident consequence management as defined in this document. This process includes four primary steps:

• Step 1: Form Required Planning Teams;

• Step 2: Understand the Situation;

• Step 3: Determine Chemical Incident Consequence Management Goals and Objectives (both overarching and plan-specific); and

• Step 4: Plan Development.

This multi-step process applies to the various consequence management-related plans described in Section 2.4, among various others that may be required as the incident response and recovery effort evolves.

This process is drawn from the FEMA Operational Planning Manual (FOPM), FEMA P-1017, which provides a basic template for risk-based planning and decision making that can be easily tailored to support integrated chemical incident consequence management needs. This process can be used to support pre-incident deliberate planning as well as real-time crisis action planning (across various types of plans, including, but not limited to, those described in Section 2.4 above) that accounts for actual incident impacts and incident-specific resource needs. It also encompasses a Whole Community focus to ensure necessary partner and stakeholder engagement and that appropriate and sufficient research, technical analysis, and risk assessments are conducted to support to achieve the desired end-states. The various plans developed through this process in support of consequence management needs will require consistent and thorough evaluation and update across operational phases to identify any gaps which such plans did not account for sufficiently based on the specifics of the incident scenario. Hence, the consequence management planning process is also iterative in nature requiring flexibility among the various stakeholders involved in the process.

Additional technical references and background information that correspond to the individual process steps identified above are provided in the appendices to this document. Appendix A discusses available hazardous chemical-specific exposure guidelines (environmental health-based levels) and factors to consider when selecting appropriate types of values to apply at each stage of an incident (e.g., characterizing the incident, establishing consequence management goals, selecting remediation strategies and methods, and making clearance decisions). Appendix B presents example scenarios, operational phasing, and case studies based on real-world incidents and exercise events.

SLTT jurisdictions engaged in chemical incident consequence management, particularly in situations involving both wide area and site-specific contamination (including the contamination of critical infrastructure facilities where operational disruption likely will have significant impacts to one or more jurisdictions and surrounding communities), must rely heavily on the engagement and participation of multiple partners, stakeholders, and SMEs. Active engagement among appropriate Whole Community agencies and organizations will help ensure: (1) partner and stakeholder issues and concerns are addressed sufficiently in the consequence management planning and decision process, and (2) acceptability of consensus end-states (as described more generally in this document, but specific to the given incident) for consequence management activities such as safe re-use and re-occupancy of contaminated areas and specific sites (to include accepting loss of facilities, equipment, and materials for proper waste disposal if successful decontamination is not achievable).

Planning and decision making regarding chemical incident consequence management comprises three primary elements: an established UC and other jurisdiction-specific senior leadership teams, a core planning team, and a collaborative planning team. These three elements are distinguished by their specific roles and responsibilities in the planning and decision-making process.

UC and Other SLTT Senior Leadership Teams

Nationally significant or large-scale chemical incidents may have significant impacts within a single jurisdiction or, more likely, across multiple SLTT jurisdictions. Such incidents will involve the establishment of a UC structure to facilitate incident management and resource coordination across involved jurisdictions and responding agencies. The composition of the UC will vary based on incident size, scope, complexity, and the specific agencies/organizations and SMEs that need to be engaged at various points in the response and recovery effort. The UC structure will also be directly linked to SLTT appointed and elected officials and private sector officials with key decision authorities pertinent to the overall response and recovery effort. Collectively, the established UC and other SLTT leadership, supported by senior technical advisors, as needed, represents the approval authority for plans and planning products developed to support chemical incident consequence management needs. Regardless of the subject of the specific plan being developed, planners must engage pertinent senior leadership with the intent of securing direction, approval, and document validation throughout the entire planning process. The UC and other pertinent senior leaders, along with relevant technical SMEs, will convene at pivotal junctures during the planning process to review and approve the current state and future direction of the various plans considered.

Core Planning Team

In the context of chemical incident consequence management, a Core Planning Team is established to engage relevant partners and stakeholders and provide an orderly structure for the planning effort, integrating all the elements of the planning process and relevant technical expertise to meet the goal and supporting objectives, deliverables, and schedule for the specific plan under consideration. The Core Planning Team also is responsible for facilitating subordinate technical working groups charged with specific aspects of plan development and ensuring the quality of the deliverables created.

The reporting structure for the Core Planning Team will be determined by the IC/UC. The Core Planning Team may also provide support to any technical SMEs assigned directly to the ICS Command Staff or elsewhere within the ICS organization established for the incident.

The Core Planning Team is overseen by a team leader designated by the IC/UC leadership. Once assigned, the team leader begins determining the composition of the Team. Core Planning team members generally possess either specific jurisdictional authority or planning expertise and experience based on the type of plan being considered (e.g., site decontamination, clean-up, hazardous waste management, etc.). Once established, the planning team leader communicates expectations and plan milestones, schedules, and responsibilities to the group.

The Collaborative Planning Team works under the direction of the Core Planning team and includes individuals identified by the IC/UC as representing a specific program area, capability, technical area of expertise, or organization pertinent to chemical incident consequence management planning.

Team members are responsible for the development and accuracy of deliverables assigned to them by the Core Planning Team throughout the planning process.

The Collaborative Planning Team may include SMEs from FSLTT agencies; NGOs; and private-sector partners (including RPs) who have specific authorities, responsibilities, and/or capabilities pertinent to consequence management or who may have a significant stake or responsibility in the execution of the operational plan being developed. Team members should be able to speak with authority on policy, capabilities, and resources, provide technical expertise, and help ensure accountability as it relates to their parent agency or organization.

Collaborative planning team members may be called upon to:

• Provide information regarding their parent organization’s authorities, roles and responsibilities, technical capabilities, resources, etc.;
• Provide functional and technical expertise and conduct or facilitate outreach to relevant analysis;
• Develop strategies and tactics related to plan implementation; and
• Develop COAs and present briefings for senior leader approval.

Members of a Collaborative Planning Team focused on chemical incident consequence management typically represent the following types of organizations and/or functional expertise:

• Facility and property owner(s)/operator(s) of contaminated facility or facilities;
• Local planning commissions;
• SLTT-level public health, environmental protection/equity and justice, and waste management organizations;
• Federal Environmental Protection Agency (EPA) representative(s);
• Federal Occupational Health and Safety Administration (OSHA) representative(s);
• Federal Centers for Disease Control and Prevention/Agency for Toxic Substances and Disease Registry (ATSDR);
• Public Information Officer (PIO)/Strategic risk communication organizations;
• HAZMAT/waste management consultants and/or clean-up firm(s);
• Community-based organization(s); and
• Others as required based on the incident scenario and UCG needs.

Scoping the Plan

The Core Planning Team should scope all relevant consequence management plans based on the identified issue, hazard, or threat that needs to be addressed within or across specific operational phases of the response and recovery effort. This includes, but is not limited to, the specific types of plans identified in Section 2.4 above. Specific critical information requirements (CIRs) pertinent to such plans typically are developed in the context of particular incident that, in turn, are used in scoping a plan. For a nationally significant or large-scale chemical incident, these CIRs normally will include, but are not limited to, the following:

• What was the definitive chemical(s) involved in the incident?
• What are the toxicological properties and environmental fate and transport of those chemical(s)?
• Which facilities (both homes, government facilities and businesses) and publicly accessible areas are suspected or confirmed to have chemical contamination present?
• What specific areas of those facilities or specific materials, and equipment were determined as either suspected or confirmed to have contamination?
• Are these suspected or confirmed contaminated facilities, materials, and equipment privately-owned or government-owned, and who will be responsible for performing clean-up and waste removal, appropriately?
• For both personnel and equipment decontamination, what methods were found effective to prevent contamination spread or cross-contamination?
• What are the required decontamination materials, supplies, and equipment required to conduct clean-up and waste removal operations?
• Are there existing standards for defining sufficient decontamination levels for the chemical(s) involved, and what are the acceptable methodologies to detect and quantify those levels?
• Are there cost limitations in performing decontamination and waste removal for the areas impacted, and “who pays?”
• Are there specific cultural, ethnic, environmental justice, or socio-economic considerations when performing decontamination and waste removal operations?

Additionally, proper scoping the plan and associated requirements will guide planners in identifying partners, stakeholders, and SMEs that should be involved in the planning process. Such individuals are identified and included as the planning process evolves; the planning team leader will be responsible for managing the level and breadth of their engagement.

Engaging the Whole Community

Engaging the Whole Community experience has shown that it takes all aspects of a community (non- profit; the private sector; community-based organizations; and the public, including survivors) -- not just the government -- to effectively prepare for, protect against, respond to, recover from, and mitigate large- scale chemical incidents. The aspects of a UCG involved in chemical incident consequence management, therefore, must sustain and further strengthen its already strong partnerships and relationships, and effectively mobilize and support resources, expertise, and capabilities from all levels of government, the private sector, the non-profit community, and the public. The UCG should work with partners and stakeholders from every sector to enable communities to develop collective, mutually supporting consequence management strategies and methods. Engaging the whole community in the planning process can provide the added benefit of bringing together diverse points of view and developing atypical avenues of support.

2.6.2. STEP 2—UNDERSTAND THE SITUATION

This step in the planning and decision process emphasizes the importance of understanding the situation before developing or updating plans related to chemical incident consequence management. In chemical incident response, situational assessment includes the incorporation of information on the specific chemical(s) involved, facilities and other items contaminated, the extent of contamination, impacts on public health and the environment, and other CIR described previously.

Information Analysis Process

Information analysis is the process planners use to inform both strategic and operational decisions. Based on the scope of the plan, various aspects of the collective planning team are engaged to identify, research, collect, and assess the information that will drive decision making and provide a factual basis for the specific plan under consideration. Information analysis is a collaborative effort that depends on teamwork and cooperation among all planning team members, including leadership, partners, stakeholders, and SMEs.

The information analysis process encompasses two main areas: 1) research and 2) analysis.

Research

Research occurs throughout the planning process to help refine the intent, scope, and objectives of specific plans and implementation tasks that are developed to address various consequence management needs. Research also helps to identify secondary and tertiary effects of the incident on people, infrastructure, and the environment. For example, if a specific decontamination method is used to remediate a specific chemical(s) of concern, what are the degradation by-products? Are these products toxic to human health and/or the environment? Is there then a requirement to remove the degradation product after primary decontamination is performed? Comprehensive research is essential in the development of specific plan components.

The planning team leader will scope the extent of the research required based on the size, scope, and complexity of a given chemical incident. Research that is specific to chemical incident consequence management needs should include the following:

• Contamination issue regarding workers and the public;
• Specific facilities, materials and equipment determined to be contaminated;
• Extent of area and site-specific contamination (e.g., all rooms, just floors, concentrations);
• Building components of contaminated facilities, materials and equipment (e.g., concrete, linoleum, wood, metal, glass, porous or nonporous);
• Weather conditions (may impact contamination spread or possibly degradation);
• Topographical characteristics of suspected or confirmed contaminated areas;
• Political, cultural, ethnic, and socioeconomic considerations involving suspected or confirmed contaminated areas and/or sites;
• Transportation corridors for personnel and equipment (both manual, light, heavy or medium mobile vehicles);
• Access to water and power; and
• Known methods & required and effective decontaminants and materials.

The following major information categories should be considered when conducting research for chemical incident consequence management:

• Operational Environment;
• Authorities and Capabilities; and
• Resource Limitations and Shortfalls;

The operational environment encompasses the environment and geography of the areas requiring characterization, remediation, and decisions regarding site re-use/re-occupation. This encompasses relevant demographic, historical, cultural, and socioeconomic factors, political sensitivities, and the area geography. Also included are the incident footprint, political boundaries (e.g., city and county or property lines) and other factors that may impact how remediation and other necessary activities may be implemented. Large geographic areas or complex political boundaries may require planners to consider unique ways to structure the incident organization to effectively support consequence management operations. Finally, operating environment considerations includes research on the contaminants, proposed decontamination methodologies and equipment, and potential for decomposition products resulting from certain decontamination methods or from exposure to various potential weather conditions.

Capabilities are the means to accomplish the remediation effort successfully. Capabilities not only include equipment, training and supplies to conduct certain decontamination and cleanup activities, but also, rely on authorities, policies, programs, staff, funding and available resources to implement those capabilities.

Resource limitations and shortfalls are limitations that restrict the way in which a resource(s) can support consequence management activities. This may include, for example, water or power access, or limited materials to support the operation of certain types of decontamination equipment.

Analysis

Analysis involves the detailed examination of information in order to gain a clearer understanding of the situation and surrounding environment. Analysis also helps to drive the development of specific planning products. The planning team conducts analysis of the information they have collected through the research process in order to have a clear understanding of what the plan must address, and a factual basis for the facts, assumptions, and decisions reflected in the plan.

Based on the information collected during the research process, subsequent analysis should be able to provide the following information:

• Geographic locations of confirmed contaminated areas based on field surveys;
• Geographic locations of suspected, but not yet confirmed contaminated areas;
• Known composition of materials suspected (e.g., concrete, linoleum);
• Estimated square footage or volume of contaminated areas, materials, and equipment;
• Identification of areas and types/sizes of facilities, equipment and materials that have a high probability of being decontaminated effectively; and
• Identification of areas and types/sizes of facilities, equipment and materials not likely to be decontaminated either due to the complexity, size, and/or significant costs incurred.

Analysis also supports the development of potential strategies/methodologies to accomplish key consequence management tasks:

• For areas not deemed appropriate for remediation, the identification of disposition options (e.g., demolition/removal for waste disposal);
• Based on the size and physical geometry areas or specific sites targeted for remediation, an estimate of the amount and type of equipment, supplies. and materials required to conduct remediation operations;
• Identification of government versus private owner/operator responsibilities and funding for decontamination, hazardous waste removal, and other services;
• Identification of either government and/or contracted performers to implement selected remediation strategies;
• Identification of downstream areas where chemical(s) of concern and/or decontaminant may flow and cause significant impacts; and
• Identification and estimation of the duration of critical infrastructure impacts that may result from select remediation activities.

Critical facts and assumptions are identified as an outcome of the analysis process. Plans are based on substantiated facts such as the nature of the threat or hazard and anticipated operational impacts. Assumptions represent information accepted by planners as true in the absence of facts. The use of assumptions allows planners to further characterize the specifics of the incident at hand, identify potential response requirements, and move forward with or refine the planning process.

Planners should compile the results of the analysis process into planning factors. Planning factors encompass physical effects, operational impacts, facts, and assumptions which result from the careful study of the specific incident scenario the plan is intended to address. As a tool for placing research and analysis in operational context, planning factors help ensure that planners develop appropriate COAs for relevant tasks and activities.

Planning factors may have both qualitative and quantitative aspects. In the context of chemical incident consequence management, planning factors may be expressed as follows:

• Contaminated facilities include the following:

• Building A (Exterior and 3 stories and estimated 10,500 square feet);

• Building B (Exterior and 1st floor only estimated at 2500 square feet);

• Parked vehicles around Buildings A and B (Approximately 50 vehicles (e.g., 10 pickup trucks, 20 sedans, 10 motorcycles, 10 commercial 4-wheel trucks); and

• Common areas, sidewalks, and outdoor parking around Buildings A and B (approximately 20,000 square feet).

• Decontamination capability determined effective:

• Chemical XXX estimated 5000 gallons;

• Estimated personnel: 300 personnel trained and qualified; and

• Estimated time for decontamination: 30 calendar days operating 10 hours per day (daytime only).

• Estimated decontamination costs: >$5 million

Planners should also identify anticipated shortfalls/challenges as part of the analysis process. The following are typical examples:

• Limited quantities of water or decontamination solution available at any given time to perform remediation;
• Political, social or ethnic sensitivities to the areas requiring decontamination (e.g., statutes, paintings, computers, records);
• Availability of trained and qualified personnel to perform decontamination; and
• Maintaining site security.

2.6.3. STEP 3—DETERMINE GOALS AND OBJECTIVES

In this step, planners determine the operational priorities, develop the mission statement, describe the end state, identify relevant timelines, and establish goals and objectives for the plan under consideration. These plan components are important to define what mission success will look like in a given consequence management effort. This effort culminates in an information analysis brief (IAB) developed for the IC/UC and other senior leaders to seek further guidance and gain approval for further plan development including COA development.

Describe the End State

The end state describes the desired situation that will exist when a given chemical incident consequence management plan is successfully implemented and all supporting operations are concluded. The IC/UC and other Whole Community senior leaders typically determine the end state; the planning team may refine the end state to provide more specific detail to meet senior leader expectations.

Develop the Mission Statement

The mission statement defines a plan's purpose, primary operational objectives, and the key measure or measures of the plan’s success. It also demonstrates the manner in which the intent and scope of the plan will be addressed, based on the incident scenario and the physical and operational impacts. More than any other element of a plan, a clear definition of the mission (and supporting tasks) enables unity of effort and consistency of purpose among the groups and activities involved in both developing and executing the plan. The mission statement should be a short paragraph or sentence that describes what must be accomplished to achieve success clearly articulating the elements or essential tasks related to “who, what, when, where, and why” of the plan.

The Core Planning Team, with input from the Collaborative Planning Team, presents the mission statement to the UCG and other senior leaders for review and approval, typically as part of the IAB process. Specific steps for developing the mission statement include the following:

• Identify the specified and implied tasks the planning team is trying to address;
• Identify the mission-essential tasks from among these specified and implied tasks (defined as a task(s) of such importance that without its completion the mission will fail; and
• Combine the purpose, end state, and mission essential tasks into a specific and measurable description of the mission objectives.

Once these steps are completed, the Core Planning Team should verify that the mission statement answers the following questions:

• Does it clearly articulate the end state or result of the plan under consideration?
• Does it reflect the goals or objectives that the plan is intended to accomplish?
• Does it identify who is responsible for plan implementation?

Develop Objectives

Incident objectives ultimately establish what the execution of the plan needs to achieve. Understanding the situation, developing corresponding requirements, and determining priorities are vital in this process. Objectives should be clearly stated and include attainable outcomes toward which every task is directed. Objectives define operational requirements that the organization must meet to achieve success.

Objectives often also identify who is responsible, timelines, and a general geographic location or area to which the objectives apply. Planners should endeavor to make each objective measurable, as approved objectives will drive the type or amount of capability that will need to be provided.

The Core Planning Team must ensure that objectives support accomplishing the plan’s mission. Objectives should reflect an understanding of the operational environment and the problem, while describing an approach for achieving the desired end state. As the planning process continues, planners translate the objectives into tasks that directly support the overall mission.

Identify Key Tasks

Chemical incident consequence management, dependent on geographic extent, complexity, number of sites impacted, etc., typically involves the following key time-phased activities:

• Assessment and Evaluation (e.g., identification of all areas potentially contaminated to include materials of the facilities, equipment or grounds);
• Deployment and Staging (e.g., ground and decontamination equipment, personnel, vehicles);
• Preparation (e.g., removal of items deemed unable to be effectively decontaminated to make areas accessible that can be decontaminated, set-up of equipment or personnel decontamination corridors);
• Operations (e.g., conduct of specific remediation activities);
• Evaluation and Corrective Action (e.g., verification that determined “safe” levels achieved in decontamination process and if not, another decontamination effort is employed);
• Re-use/re-occupancy of remediated areas/sites; and
• Demobilization.

Brief Senior Leaders

During the IAB, the planning team leader and other members of the team present the results of research and analysis in an organized manner and review the threat or hazard in terms of community and operational impacts. The IAB represents a key decision point for leadership to approve, modify, or redirect the intent of the plan under consideration.

The IAB is intended to ensure Senior Leadership: (1) concurs that the core planning team has conducted the appropriate research and analysis to enable a comprehensive understanding of the situation; (2) approves the analysis conducted; and (3) directs planners to proceed with the planning process.

The IAB typically includes the following:

• Identification of Core and Collaborative Planning Team members;
• Detailed information reflecting the research/analysis accomplished, including situation, geography, incident impacts, capabilities, risks, resources, modeling, and simulations;
• Detailed information on applicable SLTT jurisdictions, mission partners, and stakeholders, demographic and socioeconomic factors, risks, and capabilities;
• Facts and assumptions;
• CIRs;
• Mission statement;
• Desired end state;
• Operational phases;
• Quantifiable draft incident objectives and mission-essential tasks; and
• Planning factors (include data such as population demographics [e.g., affected population, number of casualties and fatalities] and structural impact to the affected area).

The UCG and other FSLTT senior leaders approve the IAB allowing the initiation of COA development.

2.6.4. STEP 4—PLAN DEVELOPMENT

COA Development

COAs provide the IC/UC and other senior leaders with options to consider and, ultimately, select. A fully developed COA explains who does what, and when, to achieve the desired outcome. It also identifies the resources, capabilities, and information requirements to carry out an identified strategy.

The Core Planning Team, supported by the Collaborative Planning Team and other relevant SMEs (e.g., private contractors charged with performing remediation efforts), develops, evaluates, and ultimately recommends COAs for IC/UC and other senior leader review/approval. The recommended COA or COAs must represent the best way of achieving the end state, mission, and objectives laid out in the previous step of the planning process.

Depending upon the scale and complexity of chemical consequence management efforts, there may only be one COA presented, representing a fairly “straight forward” approach with no anticipated deviations expected to achieve the given end state, mission, and objectives. However, in large-scale chemical incidents characterized by significant size and complexity, several COAs may be required to be developed, evaluated, and, in some cases, a few COAs executed either at the same time or across operational phases of response and recovery.

All COAs developed must meet the following criteria:

• Suitability: Does it accomplish the objective or mission, and comply with the senior leader’s intent?
• Feasibility: Will it work within established authorities, capabilities, and limitations?
• Acceptability: Does the solution justify the cost? Does it consider things like environmental equity and justice?
• Distinguishability: Is it distinct from the other options presented?
• Completeness: Does it fully incorporate plan objectives and tasks, along with major resource requirements (including staff, teams, facilities, supplies, equipment and transportation)?

COA Analysis

Assessment criteria provide planners with benchmarks for estimating each COA's potential for success, and for weighing the risks and benefits associated with each COA presented. Assessment criteria are characteristics against which the planning team analyzes and scores each option, resulting in a profile of each COA that provides relative strengths, weaknesses, risk, and values in different categories.

Assessment criteria may entail a qualitative approach. This approach accommodates uncertainties in the operational environment (e.g., unsure of whether all areas were determined to have been contaminated). Examples of a qualitative assessment criteria may include the following:

• Timeliness: COA provides an efficient process to accomplish remediation within matter of weeks;
• Effectiveness: COA uses proven decontamination process found to reduce contaminant levels or at least neutralize the contaminants’ potential health effects; and
• Wastes Generated: COA will generate minimal hazardous and non-hazardous wastes.

Assessment criteria may entail a quantitative approach. This approach requires a well characterized and fairly stabilized operational environment (anticipating less or no changes over time). Examples of a quantitative assessment criteria may include the following:

• Timeliness: COA provides an efficient process to accomplish remediation within 15 calendar days;
• Effectiveness: COA uses a proven decontamination process found to reduce contaminant levels to less than 0.01% of the detected amounts, or below detectable levels; and
• Wastes Generated: COA will generate less than 25 metric tons of both hazardous and non-hazardous wastes.

Once the assessment criteria are developed, the planning team develops criteria ratings. Each criterion selected by the workgroup will need to be further broken out into measurable ratings. Typically, a rating system from one to five provides a sufficient level of detail to distinguish between COA scores, but does not represent a greater degree of specificity than the planning team can determine. A notional rating system template is provided below.

Depending upon the plan’s approved end state, mission, objectives, the planning team also may decide to assign weighted numerical comparisons to the various ratings. For example, if the planning team determines that “timeliness” is a criterion that should be weighted higher than “wastes generated,” a multiplier may be applied to the timeliness rating. Otherwise, the planning team may wish to treat all criteria in a non-weighted numerical comparison.

Other assessment criteria methodologies may include the following:

• Qualitative Narrative Technique: The planning team summarizes comparison of all COAs by analyzing strengths and weaknesses, or advantages and disadvantages; and
• Plus/Minus/Neutral Comparison: Positive means a positive influence in meeting criteria, negative means a less than optimal influence in meeting the criteria, and a “0” means a neutral influence.

The following represent key considerations in selecting the appropriate COA comparison techniques:

• Numeric Comparison
  • Planning efforts have sufficient time to generate detailed information that will allow the team to thoughtfully and accurately assign numerical values for each COA by defined criteria; and
  • The UCG has defined high-priority guidance regarding objectives and criteria, which make weighting of COAs an important consideration.

• Narrative Comparisons
  • Planning efforts have sufficient time to generate detailed narrative information regarding COAs; and
  • COAs are multi-faceted and require detailed descriptions to show how they are distinct from one another.

• Plus/Minus/Neutral Comparisons
  • Planning efforts have less time and need to rapidly assign values to COAs is more critical; and
  • More detailed information regarding individual COAs is unavailable.

COA Recommendation

The planning team recommends COAs to the IC/UC and other appropriate FSLTT senior leaders based on the evaluation criteria developed. The COA recommendation takes into account the risks and benefits of each COA presented. The planning team may recommend a particular COA to senior leaders even if the factors such as cost are high, but the COA represents a more effective approach (e.g., the COA includes an extensive decontamination technique where determined safe levels are achieved, but requires the most expensive equipment, personnel, and supplies to implement). In addition, the COA with the highest score may not necessarily be the best option for recommendation, but having the scoring criteria allows the COA workgroup to consider each criterion, the overall score of each COA, and identify the best option for recommendation. In the context of chemical incident consequence management, various COAs may be selected for implementation, but in a timed phase approach. Therefore, the planning team should not take a “one and done” perspective when making COA recommendations.

COA Decision Brief

The COA brief typically includes the following key components:

• Incident Situation (e.g., type and extent of contamination, areas and sites impacted, vulnerable populations impacted, etc.)
• Mission statement
• Senior leader’s intent
• Objectives
• Operational phases
• Planning factors
• CIRs
• List of participants in COA planning
• COA development and evaluation (including COAs not selected)
• Recommended COAs
  • Operational concept
  • Resources required
  • Core Capabilities engaged

• Path forward (timeline and next steps)