![](media/image1.jpeg){width="2.4270833333333335in"
height="0.7083333333333334in"} **National Association of Regional
Councils**

1666 Connecticut Avenue, NW Suite 300

Washington, DC 20009

202.986.1032 (tel) 202.986.1038 (fax)

**www.narc.org**

October 15, 2007

Re: Docket ID No. FEMA-2007-0008

Dear Ms. Pryce,

Please accept the following comments on behalf of the National
Association of Regional Councils (NARC) to the National Advisory Council
for consideration as they plan their agenda and determine next steps.

NARC is the national voice for regionalism and advocates for regional
cooperation as the most effective way to address a variety community
planning, development and infrastructure issues. NARC's members are
regional councils (RCs), which are integral to determining and executing
regional solutions for transportation, economic and community
development, homeland security and environmental issues. As it stands
today, regional councils are involved in federal, state and local
strategies to plan, prepare and respond to homeland security needs, but
still require consistent recognition, expanded authority and funding
from the federal level. Therefore, NARC and its members request that
regional councils throughout the nation are included are important
partners and necessary means to employ successful regional approaches to
national homeland security needs.

As you are well aware, events like 9/11 and Hurricanes Katrina and Rita
underscore the importance of timely homeland security planning and
execution to protect the safety and security of our families,
communities and country. In order to bolster our nation during both pre
and post-disaster, it is necessary to recognize and include regional
authority to support the roles regional councils play in coordination,
planning and sustained response on a multi-city, county, state and
regional basis.

Regional councils are referred to in a variety of ways -- Councils of
Governments (COGs), Metropolitan Planning Organizations (MPOs), Rural
Planning Organizations (RPOs), etc. -- and all serve the interests of
local and regional communities -- urban, rural, large and small.
Currently, there is an existing network of nearly 500 regional councils
and planning organizations throughout the country, which bring elected
officials from cities, counties, towns, and townships together to
address and develop homeland security action and preparedness plans.
These regional organizations have over forty years of expertise in
regional coordination and management with federal, state and local
governments, as well as the private sector, and represent 35,000 of the
39,000 local, general purpose governments in the United States
(counties, cities, townships, towns, villages, boroughs). Regional
councils are proven effective in overcoming multi-jurisdictional
barriers while preparing necessary response plans and assisting our
nation's heroic first responders.

Often, regional councils are an overlooked asset in homeland security
processes. However, states like Texas demonstrate the significant role
regional councils play in the wake of an emergency. During the 2005
hurricanes, regional councils from around the state were tested in their
emergency preparation and response, utilizing their evacuation and
shelter planning in a coordinated and proactive manner. According to
Governor Perry's Task Force on Evacuation, Transportation and Logistics,

> *The Governor's 24 Councils of Governments (COGs) are well-organized
> regions that provide a useful framework for regional planning. COGs
> should coordinate the development of regional evacuation plans by
> bringing together hurricane evacuation areas, state agencies, local
> governments and private stakeholders...Regional response and
> evacuation plans must be exercised regularly.*
> <http://www.txregionalcouncil.org/ep/EvacuationTaskForceReport.pdf>

Even a 2004 U.S. Government Accountability Office report further states,

> *Particularly since the events of September 11, 2001, regional
> approaches have been recognized as a key way to address the threat of
> terrorism. In many urban areas, the threat of terror is regionwide,
> and resources for responding to that threat are distributed among many
> jurisdictions. Therefore, the most effective responses are coordinated
> and planned across the region, rather than being
> jurisdiction-specific.... Regional organization structures,
> flexibility to account for local conditions, and strategic planning
> are key characteristics of regional coordination. Given the important
> role that regional planning and governance can play in improving
> national preparedness, these developments warrant continuing
> congressional oversight.*
>
> <http://www.gao.gov/new.items/d041009.pdf>

The U.S. Department of Homeland Security (DHS) in their Funding Year
2006 (FY06) and Funding Year 2007 (FY07) Homeland Security Grant Program
(HSGP) guidance included an existing definition of "local unit of
government," (page 54 of the FY06 HSGP guidance and page 9 of the FY07
HSGP guidance) which includes regional councils as eligible participants
by stating the following:

> *As defined in the Conference Report accompanying the Department of
> Homeland Security Appropriations Act of 2006, the term "local unit of
> government" means "any county, city, village, town, district, borough,
> parish, port authority, transit authority, intercity rail provider,
> commuter rail system, freight rail provider, water district,
> **regional planning commission, council of government**, Indian tribe
> with jurisdiction over Indian country, authorized Tribal organization,
> Alaska Native village, independent authority, special district, or
> other political subdivision of any State."*

In both the past and present, NARC has been dedicated to better
incorporate this understanding of regional council organizations at the
federal level for homeland security purposes. In 2003, NARC and its
members worked with Congressman Jack Kingston (R-GA) to push forward a
stand-alone piece of legislation that would provide funding for RCs to
develop and execute response plans in the event of man-made or natural
disasters. We have revived this effort in language inclusion for the
FY2008 DHS authorization bill and are working with Senate Homeland
Security Committee Chairman Joe Lieberman (I-CT). This new effort would
improve current language in the authorization bill to more explicitly
include RCs in homeland security activities, as well as establish a new
grant program that would provide funding for approved RC grantees for
homeland security planning and response. Also, NARC has submitted public
comment for the recently released Department of Homeland Security (DHS)
draft National Response Framework (NRF) and the White House National
Strategy for Homeland Security, which include community organizational
approaches that recognize the importance of regional coordination.
NARC's recommended language urges to codify through changes to general
phrasing that includes of all entities identified in the DHS guidance
definition above. In fact, the White House finalized strategy, which was
released earlier this week, includes NARC's comments by including
regions as an integral part in homeland security strengths and
capabilities.

NARC's efforts and those of the on-the-ground RCs are critical to
sustaining and improving vital homeland security functions, which are
imperative to the safety and security of communities. Regional councils
are the experts in local homeland security activities and, therefore,
require expanded authority and consistent specific recognition from
federal level strategies to plan, prepare and respond to natural and
man-made disasters alike.

All levels of government -- local, State and Federal -- are overwhelmed
with a flurry of constant homeland security needs. It is necessary,
therefore, to always include the role of regional councils in assisting
and complimenting homeland security initiatives for localities and
regions. The role of regional councils does not burden or hinder
emergency operations or usurp any existing federal, state or local
agency or private sector function in disaster recovery and response.
Rather, RCs help with efficient, effective solutions that leverage and
maximize homeland security resources even further to help local, State
or Federal efforts.

As a national partner representing the local level government
organizations, we welcome an opportunity to discuss how we can be of
assistance, work with and support the National Advisory Council. We urge
the NAC to incorporate the voice and experience of regional councils as
you move forward. For your review are two attached examples from Texas
on how regional councils have functioned in homeland security
situations.

Please do not hesitate to contact NARC staff -- Shannon Menard
(<Shannon@narc.org>) or Peggy Tadej (<tadej@narc.org>) -- if they may be
of further assistance. Thank you.

Sincerely,

![](media/image2.png){width="2.75in" height="0.6319444444444444in"}

Cameron Moore

Executive Director

![](media/image3.png){width="2.375in" height="1.625in"}

**Submission from John Kiehl, Regional Services Director,**

**Panhandle Regional Planning Commission -- Amarillo, TX**

Sunday, March 12, 2006, was literally one of the darkest days in the
history of the Texas Panhandle. On that day, two major wildfires erupted
and a record was set for the most acres burned in a single day. By
week's end 1,681 square miles of land had been scorched; an area larger
in size than the state of Rhode Island.

The Panhandle Regional Emergency Management Advisory Committee of the
Panhandle Regional Planning Commission (PRPC) had completed a draft of a
new regional response plan just weeks before the fires occurred. The
plan called for the development of an innovative response feature -- the
Regional Coordination Center (RCC). The purpose of the RCC was to work
at the regional level to request and stage response assets that could
then be deployed at the discretion and direction of the Incident
Commander. This behind the scenes resource function allowed the Incident
Commander to concentrate on how available resources could best be used
rather than having to expend additional time in locating and positioning
resources.

Though this approach had not been used before, it was immediately
employed and physically co-located at the Disaster District Committee
(DDC). PRPC staff manned the RCC and began putting together fire task
forces comprised of elements from departments 50 miles or more removed
from the fires. Each task force was put under the leadership of one of
the team members and that team leader was responsible reporting into the
Incident Commander when the team arrived on scene. PRPC directed the
team elements to rally at pre-determined staging points. PRPC staff
continued to serve in this capacity throughout the week of the main
fires. Later in the month when more fires broke out, the RCC was stood
up once more and the resource scenario was repeated.

The benefit of using this approach is that it provides for a much more
coordinated and organized response to large scale incidents. By amassing
assets in a controlled fashion, the incident can be dealt with more
effectively and expediently.

The RCC concept will be further refined in the PRPC's new Regional
Catastrophic Response Plan. However, in this new document, the function
will now be referred to as the Multi-Agency Coordination Center.

**About PRPC**

The Panhandle Regional Planning Commission is a voluntary association of
cities, counties, and special districts in the Texas Panhandle.
Established in 1969, the Planning Commission assists local governments
in planning, developing, and implementing programs designed to improve
the general health, safety, and welfare of the citizens in the Texas
Panhandle.

**Submission from Ed Schaefer, Emergency Preparedness Planner**

**Capital Area Council of Governments -- Austin, TX**

The Capital Area Council of Governments (CAPCOG), which serves Bastrop,
Blanco, Burnet, Caldwell, Fayette, Hays, Lee, Llano, Travis, and
Williamson Counties, began coordinating regional homeland security and
emergency management preparedness activities in 2002. The focus has been
to leverage resources in order to enhance the preparedness of local
governments and to do so in a way that avoided duplication while
building the capacity for coordinated regional response. This approach
has focused on several key initiatives:

-   Enhancing interoperable radio communications---CAPCOG's
    jurisdictions worked cooperatively to purchase and install equipment
    to ensure that emergency response personnel from across the region
    are able to communicate with each other. These enhanced capabilities
    were instrumental in coordinating an effective multi-agency
    response.

-   Developing local emergency management plans---CAPCOG personnel and
    contractors funded by the State of Texas have worked with counties
    and cities across the region to increase the number of jurisdictions
    that have up-to-date emergency management plans. This planning
    process ensured that the affected jurisdictions had a framework for
    their emergency response activities.

-   Developing regional mutual aid agreements and a regional mutual aid
    plan---CAPCOG jurisdictions adopted a region-wide mutual aid
    agreement and a regional mutual aid plan that clearly defined the
    roles and responsibilities of each jurisdiction in requesting and
    providing mutual aid. This included recruiting, training and
    equipping a cadre of Regional Mutual Aid Coordinator; this group
    responded directly to cities and counties directly affected by the
    June 2006 flood, providing much needed assistance to local emergency
    management personnel.

-   Implementing a regional emergency notification system---Using a
    commercially-available software application, CAPCOG developed and
    installed a system capable of telephonically notifying local
    populations of impending or actual hazards. During the June 2006
    flood and its aftermath, the system made 126,381 calls to warn
    citizens of hazards such as floodgate operations and the need to
    boil drinking water.

-   Implementing a regional installation of the WebEOC emergency
    information software application---This system allowed local
    governments across the region to share critical information in order
    to maintain situational awareness and anticipate requests for mutual
    aid resources.

-   Team building---Frequent meetings of key personnel provided a forum
    for development of relationships that led to enhanced effectiveness
    and efficiency during the response to the flood. Officials from
    affected jurisdictions cited these relationships as being essential
    in obtaining and utilizing the resources that they needed in order
    to manage the flood and its aftermath.

    **About CAPCOG**

The Capital Area Council of Governments (CAPCOG), formerly known as the
Capital Area Planning Council (CAPCO),  was organized in 1970 to serve
local governments in its ten-county region, known as State Planning
Region 12. CAPCOG is a regional planning commission organized under
Chapter 391, Local Government Code, and is one of 24 within the State of
Texas.

The primary focus of CAPCOG is to serve as advocate, planner and
coordinator of initiatives that, when undertaken on a regional basis,
can be more effective and efficient. These include emergency services,
elderly assistance, law enforcement training, criminal justice planning,
solid waste reduction, infrastructure development, and housing and
economic development.