The 30-day comment period for the National Response Framework (NRF), released Sept. 10, is coming to a close but the Department of Homeland Security (DHS) is still encouraging responses all on aspects of the framework while promising a serious review of comments received.

"The core National Response Framework and the online NRF Resource Center, those two combined really make the National Response Framework," Johnson declared. "We want to make certain, when we publish this final version of the Framework in November, that people embrace it and that we use it for its intended purpose.

"Rest assured that we are going to read and adjudicate every one of those comments that we can," he added. "We will make sure at the end of the day that we have reached our target audience—federal players, state and local players, the private sector, non-governmental organizations and even individual citizens in terms of individual preparedness."

As of Sept. 26, Johnson revealed DHS had received about 120 comments so far and also had collected criticism from press accounts after the initial release of the Framework. Prior to the public comment period, DHS released the NRF to federal stakeholders and received about 850 comments in response. Many of those comments were duplicative, but DHS addressed more than half of them by making accommodations or changes in the NRF document to reflect federal perspectives.

DHS also has held outreach sessions to solicit feedback from specific communities on the proposed NRF materials, meeting with federal partners as well as the private sector at the US Chamber of Commerce; non-governmental agencies at the American Red Cross headquarters; emergency mangers at a conference of the National Emergency Management Association; and state and local business partners at a consortium meeting. DHS also held an outreach teleconference "to thousands of police and fire stations and city government facilities across the country," Johnson said.

A great deal of the feedback so far has been positive. Stakeholders have read the initial 78-page core document and then have gone online to read the additional materials to understand how it all comes together.

"We have gotten a lot of favorable comments on what a nice job we have done to make a useful, credible document," Johnson remarked.

"We think we have captured lessons learned from [Hurricane] Katrina, which were significant, and those are reflected in the document. We have recognized the need to have a document that people would actually read, absorb, learn and then use in their practice. By putting out a 78-page document with the online to back it up, we have provided a more practical document than we did with the old National Response Plan," he continued. "We are pleased with the concept of trying to write a document that addresses the executive that makes the decisions as well as the practitioner."

Executives and decision-makers are able to read the core document in several hours and understand the mechanics of national response far better than they would have with the entire National Response Plan, which remains in effect until publication of the final Framework, Johnson asserted.

Johnson pointed out that the NRF improves support for the National Incident Management System and introduces vital response doctrine for how to implement the Framework.

"I see this as an advancement and a move forward with how we as a nation can really have a more consistent and response across all jurisdictions," he said.

Post Katrina Management Reform Act

Some initial criticism from the press dealt with confusion over how DHS and FEMA would respond to a crisis in compliance with the Post Katrina Management Reform Act, where Congress designated FEMA as the lead federal agency in response to a disaster.

The NRF describes the roles of a principal federal officer (PFO), coordinating federal forces on behalf of the secretary of Homeland Security, and a federal coordinating officer (FCO), FEMA's coordinating official on the ground during a disaster. While some critics have interpreted those roles to be in conflict with each other, Johnson insisted they have failed to understand how broad the Framework really is.

"Most people think about response to natural disasters. This document is written for response across the all-hazard threat spectrum. The secretary would tell you, just as anybody else would, that in all natural disasters, David Paulison, the administrator of FEMA, would be in charge. He will report to the secretary but he will be in charge of the response," Johnson explained.

"But the document also applies to major oil spills, in which FEMA has a very minimal role. It also addresses response to some terrorist attacks and even cyber attacks, where FEMA doesn't have much of a role," he added. "In response to an IED [improvised explosive device] attack, FEMA would manage the response element to that, but the investigative and the rest of the elements of an IED attack would be run by somebody else.

"This document tries to accurately describe how the nation would respond to an event. Some of those events go beyond what FEMA is charged to do. Some people read it expecting that it just deals with what FEMA does, but it really is a broader document," he concluded.

To understand how the document works, stakeholders must understand "incident management" versus "emergency management," Johnson said. Incident management is a broad term that describes preventive and investigative actions related to an event, while emergency management focuses much more on the response to an event as a subset of incident management.

"The Post Katrina Management Reform Act says that the administrator of FEMA is the primary advisor to the president, the secretary and the Homeland Security Council on matters relating to emergency management. That's true, but incident management is broader," Johnson stated. "We looked through this document just before it was published. We looked at every time they used the word 'response' and every time they used the phrase 'incident management' and made sure that they conveyed the right action each time they were used."

To read the National Response Framework or to offer comment on it, visit the NRF Resource Center at www.fema.gov/nrf.