Comments to Docket FEMA-2008-0015

NIMS Credentialing of Personnel

By

Morongo Band of Mission Indians

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| * | *      | **Comment/Current**      | **Suggestion/Revision**     |
| * | *Page/ |                          |                             |
| N | Parag  |                          |                             |
| o | raph** |                          |                             |
| . |        |                          |                             |
| * |        |                          |                             |
| * |        |                          |                             |
+---+--------+--------------------------+-----------------------------+
| 1 | Whole  | Review of capitalization | "tribal" as in "tribal      |
|   | Do     | for "Tribe" and "Tribal  | government" should be       |
|   | cument | government"              | capitalized as when         |
|   |        |                          | discussing the body of the  |
|   |        |                          | Tribal governments as in    |
|   |        |                          | "State"                     |
+---+--------+--------------------------+-----------------------------+
| 2 | Pg 1   | "The *Guideline* is      | "The *Guideline* is         |
|   |        | intended to encourage    | intended to encourage       |
|   | Para 1 | interoperability among   | interoperability among      |
|   |        | Federal, State, and      | Federal,                    |
|   |        | local officials and will | [Tribal,]{.underline}       |
|   |        | facilitate deployment    | State, and local officials  |
|   |        | for response, recovery,  | and ~~will~~ should         |
|   |        | and restoration."        | facilitate deployment for   |
|   |        |                          | response, recovery, and     |
|   |        |                          | restoration."               |
+---+--------+--------------------------+-----------------------------+
| 3 | Pg 1   | "While not developed as  | "While not developed as     |
|   |        | such, the *Guideline*    | such, the *Guideline* could |
|   | Para 4 | could also serve to      | also serve to inform        |
|   |        | inform international     | international cross-border  |
|   |        | cross-border mutual aid  | mutual aid initiatives      |
|   |        | initiatives undertaken   | undertaken by States [and   |
|   |        | by States."              | Tribes]{.underline}."       |
+---+--------+--------------------------+-----------------------------+
| 4 | Pg 2   | "The purpose of          | Delete in entirety --       |
|   |        | credentialing is to      | repeated from paragraph     |
|   | Para 3 | ensure that the incident | above.                      |
|   |        | management community can |                             |
|   |        | plan for, request, and   | ~~The purpose of            |
|   |        | trust resources needed   | credentialing is to ensure  |
|   |        | for emergency            | that the incident           |
|   |        | assistance, receive      | management community can    |
|   |        | personnel resources that | plan for, request, and      |
|   |        | match requests, and      | trust resources needed for  |
|   |        | appropriately manage     | emergency assistance,       |
|   |        | officially dispatched    | receive personnel resources |
|   |        | responders. The          | that match requests, and    |
|   |        | *Guideline* provides     | appropriately manage        |
|   |        | core information to be   | officially dispatched       |
|   |        | used by all response     | responders. The *Guideline* |
|   |        | organizations, including | provides core information   |
|   |        | operational definitions  | to be used by all response  |
|   |        | for important terms and  | organizations, including    |
|   |        | the key credentialing    | operational definitions for |
|   |        | processes."              | important terms and the key |
|   |        |                          | credentialing processes.~~  |
+---+--------+--------------------------+-----------------------------+
| 5 | Pg 2   | "To achieve this, DHS    | "To achieve this, DHS and   |
|   |        | and FEMA recognize the   | FEMA recognize the existing |
|   | Para 5 | existing authority for   | authority for States [and   |
|   |        | States to regulate       | Tribes]{.underline} to      |
|   |        | mutual aid within their  | regulate mutual aid within  |
|   |        | borders and seek to      | their borders and seek to   |
|   |        | build on the States'     | build on ~~the States'~~    |
|   |        | existing processes and   | existing processes and      |
|   |        | systems to improve the   | systems to improve the      |
|   |        | delivery of interstate   | delivery of interstate      |
|   |        | mutual aid. This         | mutual aid. This            |
|   |        | *Guideline* does not     | *Guideline* does not        |
|   |        | preempt or diminish the  | preempt or diminish the     |
|   |        | sovereignty of the       | sovereignty of the States   |
|   |        | States to manage         | [or Tribes]{.underline} to  |
|   |        | response operations in   | manage response operations  |
|   |        | accordance with their    | in accordance with their    |
|   |        | laws."                   | laws."                      |
+---+--------+--------------------------+-----------------------------+
| 6 | Pg 9   | Section 2 of the Guide   | Address that the over       |
|   |        | provides an overview of  | 80,000 local governments in |
|   | Para 3 | Tribes as sovereign      | the US are creations of the |
|   |        | nations but does not     | State under State           |
|   |        | address the fact that    | Constitutions. The Guidance |
|   |        | local governments are    | apparently appears to lump  |
|   |        | political subdivisions   | local governments into a    |
|   |        | of their State.          | category as a State.        |
|   |        |                          |                             |
|   |        | "Tribal governments are  | "[Different from local      |
|   |        | sovereign nations. As    | governments, that derive    |
|   |        | such, they are           | their powers from State     |
|   |        | encouraged to review     | Constitutions and           |
|   |        | their existing rules and | Law,]{.underline} Tribal    |
|   |        | laws that apply to NIMS  | governments are sovereign   |
|   |        | and ICS and to revise    | nations. As such, they are  |
|   |        | them in accordance with  | encouraged to review their  |
|   |        | the recommendations      | existing rules and laws     |
|   |        | provided in this         | that apply to NIMS and ICS  |
|   |        | document. If tribal      | and to revise them in       |
|   |        | governments credential   | accordance with the         |
|   |        | personnel in specific    | recommendations provided in |
|   |        | conformity with the      | this document. If tribal    |
|   |        | *Guideline*, the         | governments credential      |
|   |        | credentialed person will | personnel in specific       |
|   |        | be recognized by all     | conformity with the         |
|   |        | Federal agencies and     | *Guideline*, the            |
|   |        | State and local          | credentialed person will be |
|   |        | governments that have    | recognized by all Federal   |
|   |        | adopted the same         | agencies and State and      |
|   |        | guidance."               | local governments that have |
|   |        |                          | adopted ~~the same~~        |
|   |        |                          | [similar]{.underline}       |
|   |        |                          | guidance."                  |
+---+--------+--------------------------+-----------------------------+
| 7 | Pg 9   | "In order to comply with | "In order to comply with    |
|   |        | the *Guidelines*, State  | the *Guideline~~s~~*, State |
|   | Para   | governments, in          | [and Tribal]{.underline}    |
|   | 6-8    | conjunction with local   | governments, in             |
|   |        | and tribal               | ~~conjunction~~             |
|   |        |                          | [consultation, and          |
|   |        | governments, are urged   | States]{.underline} with    |
|   |        | to:                      | [their]{.underline} local   |
|   |        |                          | ~~and tribal~~ governments, |
|   |        | ● Designate a            | are urged to:               |
|   |        | credentialing authority  |                             |
|   |        | empowered by the State   | ● Designate a credentialing |
|   |        | for overall management   | authority empowered by the  |
|   |        | of the credentialing     | State [or                   |
|   |        | functions and processes. | Tribe]{.underline} for      |
|   |        |                          | overall management of the   |
|   |        | ● Determine how the      | credentialing functions and |
|   |        | State will work with     | processes.                  |
|   |        | other levels of          |                             |
|   |        | government within the    | ● Determine how the State   |
|   |        | State and with tribal    | [and Tribes within the      |
|   |        | nations to implement the | State]{.underline} will     |
|   |        | *Guideline*."            | work with other levels of   |
|   |        |                          | government within the State |
|   |        |                          | ~~and with tribal nations~~ |
|   |        |                          | to implement the            |
|   |        |                          | *Guideline*."               |
+---+--------+--------------------------+-----------------------------+
| 8 | Pg 10  | "**GRANT INFORMATION     | "**GRANT INFORMATION        |
|   |        | RELATED TO THE           | RELATED TO THE GUIDELINE**  |
|   | 2      | GUIDELINE**              |                             |
|   |        |                          | All Federal agencies who    |
|   |        | All Federal agencies who | make preparedness grants    |
|   |        | make preparedness grants | should allow State, tribal, |
|   |        | should allow State,      | and local governments to    |
|   |        | tribal, and local        | use these funds to          |
|   |        | governments to use these | implement the *Guideline,*  |
|   |        | funds to implement the   | per NIMS Guide 0002. [State |
|   |        | *Guideline,* per NIMS    | agencies with devolved      |
|   |        | Guide 0002. Nothing in   | responsibility for awarding |
|   |        | this *Guideline*         | federal preparedness grant  |
|   |        | requires any State,      | funds to Tribes should      |
|   |        | tribal, or local         | allow these funds to be     |
|   |        | government to implement  | used to implement the       |
|   |        | this *Guideline* for     | *Guideline,* per NIMS Guide |
|   |        | mutual aid delivered     | 0002.]{.underline} Nothing  |
|   |        | exclusively within their | in this *Guideline*         |
|   |        | jurisdictional borders." | requires any State, tribal, |
|   |        |                          | or local government to      |
|   |        |                          | implement this *Guideline*  |
|   |        |                          | for mutual aid delivered    |
|   |        |                          | exclusively within their    |
|   |        |                          | jurisdictional borders [and |
|   |        |                          | no such requirement shall   |
|   |        |                          | be placed by a State on a   |
|   |        |                          | Tribe for receipt of        |
|   |        |                          | federal preparedness grant  |
|   |        |                          | funds]{.underline}."        |
+---+--------+--------------------------+-----------------------------+
| 9 | Pg 10  | **"EMERGENCY MANAGEMENT  | **"[STATE]{.underline}      |
|   |        | ASSISTANCE COMPACT       | EMERGENCY MANAGEMENT        |
|   | Para 3 | (EMAC)"**                | ASSISTANCE COMPACT          |
|   |        |                          | (EMAC)"**                   |
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