**Comments on Draft NIMS Document**

+-----+----+--------------------------+-------------------------------+
| **  | ** | **RECOMMENDED SOLUTION   | **COMMENT**                   |
| PAG | LI | LANGUAGE**               |                               |
| E** | NE |                          |                               |
|     | ** |                          |                               |
+-----+----+--------------------------+-------------------------------+
| G   |    |                          | The writers of this document  |
| ene |    |                          | have made good progress in    |
| ral |    |                          | reducing the unnecessary use  |
| C   |    |                          | of words with a "pre" prefix. |
| omm |    |                          | Where used, the created word  |
| ent |    |                          | is almost always an oxymoron. |
|     |    |                          | In most cases where the       |
|     |    |                          | prefix still appears the      |
|     |    |                          | inappropriate use can be      |
|     |    |                          | fixed either by just deleting |
|     |    |                          | the prefix, deleting the      |
|     |    |                          | entire word, or using a more  |
|     |    |                          | appropriate word. Many of the |
|     |    |                          | suggestions to follow address |
|     |    |                          | this issue -- which I         |
|     |    |                          | acknowledge may be a          |
|     |    |                          | fruitless crusade for         |
|     |    |                          | language accuracy and         |
|     |    |                          | clarity. Glaring examples     |
|     |    |                          | include the following:        |
|     |    |                          | predelegation, predesignated, |
|     |    |                          | predeployment,                |
|     |    |                          | pre-positioned,               |
|     |    |                          | predetermined, preincidnet,   |
|     |    |                          | predeploy, preestablished,    |
|     |    |                          | prehospital, preexisting,     |
|     |    |                          | pre-established. (My          |
|     |    |                          | computer's spell check does   |
|     |    |                          | not recognize most of these   |
|     |    |                          | non-words, even though they   |
|     |    |                          | have been inappropriately in  |
|     |    |                          | common use for many years.)   |
+-----+----+--------------------------+-------------------------------+
| G   |    |                          | This version of the document  |
| ene |    |                          | still contains way too much   |
| ral |    |                          | redundant text about the      |
| C   |    |                          | Incident Command System, its  |
| omm |    |                          | structure, and functions. All |
| ent |    |                          | this material is included in  |
|     |    |                          | the various ICS courses and   |
|     |    |                          | it should not be necessary to |
|     |    |                          | include it here. For          |
|     |    |                          | instance, a comment below     |
|     |    |                          | will suggest deleting Annex B |
|     |    |                          | completely, thereby reducing  |
|     |    |                          | the length of the document by |
|     |    |                          | 57 pages.                     |
+-----+----+--------------------------+-------------------------------+
| 13  |    | Restructure these pages  | The following several         |
| -23 |    | for internal             | suggested changes propose     |
|     |    | cohesiveness and         | moving text and restructuring |
|     |    | consistency with         | it with the titles shown in   |
|     |    | Preparedness as          | Figure 1 on page 13 for the   |
|     |    | described in the         | Preparedness Cycle and        |
|     |    | National Response        | provides a more consistent    |
|     |    | Framework, pages 27-32.  | message within the document,  |
|     |    |                          | and with the NRF.             |
+-----+----+--------------------------+-------------------------------+
| 13  | 2  | Delete "Roles."          | This word is not needed. The  |
|     |    |                          | following text is about       |
|     |    |                          | Preparedness as a whole, not  |
|     |    |                          | just the roles.               |
+-----+----+--------------------------+-------------------------------+
| 13  | Pa | Move this text to        | Moving this text and aligning |
| -17 | ge | current page 21, retitle | it with the titles shown in   |
|     | 1  | it as, "b. (1)           | Figure 1 on page 13 for the   |
|     | 3, | Organize," and insert it | Preparedness Cycle provides a |
|     | li | between lines 7 and 8.   | more consistent message       |
|     | ne |                          | within the document.          |
|     | 4, |                          |                               |
|     | t  |                          |                               |
|     | hr |                          |                               |
|     | ou |                          |                               |
|     | gh |                          |                               |
|     | pa |                          |                               |
|     | ge |                          |                               |
|     | 1  |                          |                               |
|     | 7, |                          |                               |
|     | li |                          |                               |
|     | ne |                          |                               |
|     | 4. |                          |                               |
+-----+----+--------------------------+-------------------------------+
| 17  | 5  | Delete "4. Preparedness  | Not needed when this portion  |
|     |    | Elements."               | of text is restructured.      |
+-----+----+--------------------------+-------------------------------+
| 17  | 6- | Move this text to page   | Internal consistency with     |
|     | 11 | 13 and insert after line | Preparedness Cycle.           |
|     |    | 12.                      |                               |
+-----+----+--------------------------+-------------------------------+
| 17  | 12 | Change "Preparedness     | The draft language is         |
|     |    | Planning" to "Plan."     | internally inconsistent       |
|     |    |                          | because "Planning" is part of |
|     |    |                          | "Preparedness," as shown in   |
|     |    |                          | Figure 1 on page 13. If the   |
|     |    |                          | editors want to keep it as    |
|     |    |                          | written, then to be           |
|     |    |                          | consistent, they should add   |
|     |    |                          | "preparedness" to every       |
|     |    |                          | occurrence of the other       |
|     |    |                          | elements in the Preparedness  |
|     |    |                          | Cycle throughout the          |
|     |    |                          | document.                     |
+-----+----+--------------------------+-------------------------------+
| 18  | 40 | Change "predelegation"   | Accuracy and clarity.         |
|     |    | to "delegation."         |                               |
+-----+----+--------------------------+-------------------------------+
| 20  | 11 | Change "b. Procedures    | Internal consistency with     |
|     |    | and Protocols," to "(3)  | Preparedness Cycle.           |
|     |    | Procedures and           |                               |
|     |    | Protocols."              |                               |
+-----+----+--------------------------+-------------------------------+
| 21  | 7  | Insert the following     | Internal consistency with     |
|     | -8 | between lines 7 and 8:   | Preparedness Cycle.           |
|     |    | "b. Organize, Train, and |                               |
|     |    | Equip."                  |                               |
+-----+----+--------------------------+-------------------------------+
| 21  | 7  | As suggested above, for  | Internal consistency with     |
|     | -8 | text on pages 13-17,     | Preparedness Cycle.           |
|     |    | below the suggested      |                               |
|     |    | insertion of "b.         |                               |
|     |    | Organize, Train, and     |                               |
|     |    | Equip," insert the       |                               |
|     |    | following between lines  |                               |
|     |    | 7 and 8," (1) Organize." |                               |
+-----+----+--------------------------+-------------------------------+
| 21  | 8  | Change "c. Training and  | Internal consistency with     |
|     |    | Exercises," to "(2)      | Preparedness Cycle.           |
|     |    | Train."                  |                               |
+-----+----+--------------------------+-------------------------------+
| 21  | 9  | Insert "(a)" at          | Internal consistency with     |
|     |    | beginning of line 9.     | Preparedness Cycle.           |
+-----+----+--------------------------+-------------------------------+
| 21  | 2  | Insert text currently on | Internal consistency with     |
|     | 0- | page 22, lines 1-13,     | Preparedness Cycle.           |
|     | 21 | between lines 20 and 21  |                               |
|     |    | and title it, "(b)       |                               |
|     |    | Personnel Qualifications |                               |
|     |    | and Certification."      |                               |
+-----+----+--------------------------+-------------------------------+
| 21  | 2  | Insert "(3) Exercise,"   | Internal consistency with     |
|     | 5- | between lines 25 and 26. | Preparedness Cycle.           |
|     | 26 |                          |                               |
+-----+----+--------------------------+-------------------------------+
| 22  | 1- | See suggestion for page  | Internal consistency with     |
|     | 13 | 21 lines 20-21.          | Preparedness Cycle.           |
+-----+----+--------------------------+-------------------------------+
| 22  | 14 | Change to read: "(4)     | Internal consistency with     |
|     |    | Equip."                  | Preparedness Cycle.           |
+-----+----+--------------------------+-------------------------------+
| 22  | 2  | Insert the following     | The addition of this NRF      |
|     | 2- | quote from the NRF, page | language is needed to         |
|     | 23 | 32 as: "d. Evaluate and  | complete the discussion of    |
|     |    | Improve."                | the Preparedness Cycle,       |
|     |    |                          | because the draft text does   |
|     |    | Evaluation and continual | not include any language      |
|     |    | process improvement are  | about this portion of the     |
|     |    | cornerstones of          | Preparedness Cycle.           |
|     |    | effective preparedness.  |                               |
|     |    | Upon concluding an       |                               |
|     |    | exercise, jurisdictions  |                               |
|     |    | should evaluate          |                               |
|     |    | performance against      |                               |
|     |    | relevant capability      |                               |
|     |    | objectives, identify     |                               |
|     |    | deficits, and institute  |                               |
|     |    | corrective action plans. |                               |
|     |    | Improvement planning     |                               |
|     |    | should develop specific  |                               |
|     |    | recommendations for      |                               |
|     |    | changes in practice,     |                               |
|     |    | timelines for            |                               |
|     |    | implementation, and      |                               |
|     |    | assignments for          |                               |
|     |    | completion.              |                               |
|     |    |                          |                               |
|     |    | **All local, tribal,     |                               |
|     |    | State, and Federal       |                               |
|     |    | entities should          |                               |
|     |    | institute a corrective   |                               |
|     |    | action program to        |                               |
|     |    | evaluate exercise        |                               |
|     |    | participation and        |                               |
|     |    | response, capture        |                               |
|     |    | lessons learned, and     |                               |
|     |    | make improvements in     |                               |
|     |    | their response           |                               |
|     |    | capabilities.** An       |                               |
|     |    | active corrective action |                               |
|     |    | program will provide a   |                               |
|     |    | method and define roles  |                               |
|     |    | and responsibilities for |                               |
|     |    | identification,          |                               |
|     |    | prioritization,          |                               |
|     |    | assignment, monitoring,  |                               |
|     |    | and reporting of         |                               |
|     |    | corrective actions       |                               |
|     |    | arising from exercises   |                               |
|     |    | and real-world events.   |                               |
|     |    | The Homeland Security    |                               |
|     |    | Exercise and Evaluation  |                               |
|     |    | Program (HSEEP) Toolkit  |                               |
|     |    | is a Web-based system    |                               |
|     |    | that enables             |                               |
|     |    | implementation of the    |                               |
|     |    | corrective action        |                               |
|     |    | program process. In this |                               |
|     |    | way, the continuous      |                               |
|     |    | cycle of preparedness    |                               |
|     |    | yields enhancements to   |                               |
|     |    | national preparedness.   |                               |
+-----+----+--------------------------+-------------------------------+
|     |    |                          |                               |
+-----+----+--------------------------+-------------------------------+
| 22  | 23 | Change "Mitigation" to   | This change is needed to      |
|     |    | Hazard Mitigation."      | differentiate this loose use  |
|     |    |                          | of the word and concept of    |
|     |    |                          | mitigation from other forms   |
|     |    |                          | of mitigation, such as        |
|     |    |                          | environmental mitigation, and |
|     |    |                          | incident mitigation.          |
+-----+----+--------------------------+-------------------------------+
|     |    |                          |                               |
+-----+----+--------------------------+-------------------------------+
| 30  | 29 | Delete "predesignated."  | This word is not needed in    |
|     |    |                          | this sentence. It is also an  |
|     |    |                          | oxymoron.                     |
+-----+----+--------------------------+-------------------------------+
| 33  | 20 | Change "Preincident" to  | Clarity and accuracy. The     |
|     |    | "Team."                  | subject of the sentence is    |
|     | (  |                          | personnel and team            |
|     | In |                          | assignments. "Preincident" is |
|     | te |                          | also an oxymoron.             |
|     | xt |                          |                               |
|     | bo |                          |                               |
|     | x) |                          |                               |
+-----+----+--------------------------+-------------------------------+
| 33  | 29 | Change "predeployment"   | Clarity and accuracy. See     |
|     |    | to "stockpiling."        | text box on page 35 for use   |
|     | (  |                          | of this term. The subject of  |
|     | In |                          | the sentence is stockpiling   |
|     | te |                          | resources in an established   |
|     | xt |                          | location prior to use in an   |
|     | b  |                          | incident. "Predeployment" is  |
|     | ox |                          | also an oxymoron.             |
|     | .) |                          |                               |
+-----+----+--------------------------+-------------------------------+
| 33  | 30 | Change "predesignated"   | Clarity and accuracy. The     |
|     |    | to "designated."         | resources are stockpiled at   |
|     |    |                          | designated warehouses or      |
|     |    |                          | other facilities, not at      |
|     |    |                          | predesignated places.         |
|     |    |                          | "Predesignated" is also an    |
|     |    |                          | oxymoron.                     |
+-----+----+--------------------------+-------------------------------+
| 34  | 31 | Consolidate these two    | Clarity and accuracy          |
|     |  - | sentences to read as     |                               |
|     | 33 | follows: "Planning may   |                               |
|     |    | include the creation of  |                               |
|     |    | new policies to          |                               |
|     |    | encourage stockpiling    |                               |
|     |    | resources near the       |                               |
|     |    | expected incident site   |                               |
|     |    | in response to           |                               |
|     |    | anticipated resource     |                               |
|     |    | needs."                  |                               |
+-----+----+--------------------------+-------------------------------+
| 35  | 4  | Delete the phrase        | Clarity. This phrase is not   |
|     |    | "including those that    | needed.                       |
|     |    | might be                 |                               |
|     |    | pre-positioned."         |                               |
+-----+----+--------------------------+-------------------------------+
| 35  | 32 | Delete "preincident."    | Clarity and accuracy. A       |
|     |    |                          | contract is a contract,       |
|     | (  |                          | whenever it is written.       |
|     | In |                          |                               |
|     | te |                          |                               |
|     | xt |                          |                               |
|     | b  |                          |                               |
|     | ox |                          |                               |
|     | .) |                          |                               |
+-----+----+--------------------------+-------------------------------+
| 36  | 2  | Delete "preincident."    | Clarity and accuracy. A       |
|     |    |                          | contract is a contract,       |
|     |    |                          | whenever it is written.       |
+-----+----+--------------------------+-------------------------------+
| 38  | 17 | Change "predeploy" to    | Clarity and accuracy. Moving  |
|     |    | "deploy."                | resources is deploying them,  |
|     |    |                          | not predeploying them.        |
+-----+----+--------------------------+-------------------------------+
| 38  | 20 | Change "pre-positioning" | Clarity and accuracy. Placing |
|     |    | to "positioning."        | resources in warehouses or    |
|     |    |                          | staging areas before an       |
|     |    |                          | incident occurs is            |
|     |    |                          | positioning them, not         |
|     |    |                          | pre-positioning them. Even    |
|     |    |                          | though the hyphenated word    |
|     |    |                          | "pre-positioning" has been in |
|     |    |                          | use for a long time, it is    |
|     |    |                          | still an oxymoron.            |
+-----+----+--------------------------+-------------------------------+
| 40  | 30 | Change "preincident" to  | Clarity and Accuracy.         |
|     |    | "standing," "existing,"  |                               |
|     |    | or "established."        |                               |
+-----+----+--------------------------+-------------------------------+
| 41  | 6  | Move the first sentence  | This sentence is not the      |
|     | -7 | to the end of the        | topic sentence of the         |
|     |    | paragraph and rewrite as | paragraph, but it contains an |
|     |    | follows: "In many cases, | important point.              |
|     |    | some resources rendered  |                               |
|     |    | may or may not be        |                               |
|     |    | reimbursed based upon    |                               |
|     |    | agreements established   |                               |
|     |    | before the incident."    |                               |
+-----+----+--------------------------+-------------------------------+
| 50  | 8  | Rewrite this sentence as | Clarity and accuracy. All     |
|     | -9 | follows: "Jurisdictions  | standing IMTs should have     |
|     |    | should consider          | designated ICs.               |
|     |    | designating ICs for      |                               |
|     |    | established Incident     |                               |
|     |    | Management Teams         |                               |
|     |    | (IMTs)."                 |                               |
+-----+----+--------------------------+-------------------------------+
| 65  | 10 | Change "preestablished"  | Clarity and accuracy.         |
|     |    | to "established."        |                               |
+-----+----+--------------------------+-------------------------------+
| 68  | 1  | Delete "prehospital."    | Not needed.                   |
+-----+----+--------------------------+-------------------------------+
| 69  | 19 | Delete "preexisting."    | Not needed.                   |
+-----+----+--------------------------+-------------------------------+
| 91- | A  | Delete Appendix B        | All this material is          |
| 148 | ll | entirely.                | contained in multiple ICS     |
|     |    |                          | courses and it should not be  |
|     |    |                          | necessary to include it here. |
|     |    |                          | This document should be used  |
|     |    |                          | as a Cliff Notes for the      |
|     |    |                          | Incident Command System.      |
+-----+----+--------------------------+-------------------------------+
| 151 | 25 | Change "predelegation"   | Clarity and accuracy. The     |
|     |    | to "delegation."         | delegated authorities for     |
|     |    |                          | emergency authorities are     |
|     |    |                          | defined in legal documents,   |
|     |    |                          | and affirmed in COG plans.    |
+-----+----+--------------------------+-------------------------------+
| 162 | 14 | Change "pre-established" | Clarity and accuracy.         |
|     |    | to "established."        |                               |
+-----+----+--------------------------+-------------------------------+
| 173 |    | Under "Resource          | There are no references on    |
|     |    | management," delete      | page 32 to pre-positioning    |
|     |    | "pre-positioning         | resources.                    |
|     |    | resources, 32."          |                               |
+-----+----+--------------------------+-------------------------------+
|     |    |                          |                               |
+-----+----+--------------------------+-------------------------------+