Performance Audit of the City of Los Angeles’
Emergency Planning Efforts and
Citywide Disaster Preparedness

EXECUTIVE SUMMARY

Background

The City’s emergency planning and disaster preparedness program involves nearly all of its departments. The roles and responsibilities of these departments vary and can be significant. The Police Department and Fire Department, with their primary public safety missions, are certainly key participants in the program. In addition, the Los Angeles World Airports and the Harbor Department have major responsibilities, due to inherent risk exposures of their operations. Because it manages major infrastructure for the City, the Public Works Department has responsibilities that touch on virtually every area of emergency response, recovery and reconstruction. Other departments can also have major emergency planning and disaster preparedness responsibilities. For example, the Parks and Recreation Department is responsible for opening shelters in the event of a major emergency or disaster and has involvement in services for the elderly and other special needs populations.

The organization of the City's emergency preparedness and response activities are established in the City Charter and Administrative Code. Activities are performed by all City departments, who are members of the Emergency Operations Organization (EOO). This group is led by the Mayor, who serves as the EOO Director. The Administrative Code also establishes the Emergency Operations Board (EOB), which governs and supervises City departments during an actual emergency, and governs the City’s response and recovery activities. This structure was established to enhance centralized command and information coordination in the event of a major emergency or disaster, and is tasked with disaster and incident-based planning duties. By ordinance, the permanent chair of the EOB is the Police Chief.

In 2000, when the new City Charter gave the Mayor direct authority over the City’s emergency management, a separate Emergency Management Department (EMD) was established. Previously, these functions were performed by staff within a division of the City Administrative Office. Led by an appointed General Manager, EMD provides coordination, management and leadership to help optimize the City’s capability to effectively respond to large scale emergencies and ensure continuity of operations and government.

To answer the question of “whether the City is prepared,” the City Controller asked for an evaluation of the structure that has been established and the activities of departments that are charged with major coordination or oversight responsibilities for the system. Therefore, although this performance audit touched on activities of all City departments, particular emphasis was directed toward the activities of the Emergency Operations Board (EOB), the Emergency Management Department (EMD) and the Mayor’s Homeland Security and Public Safety Division (HSPS).

Scope

The audit was initiated by the Controller to (a) determine the adequacy of emergency planning and disaster preparedness efforts in the City, and (b) determine whether the needs of the public would be met by the City's response to a significant emergency or disaster. Following a 2006 National Peer Review coordinated by the GAO and the U.S. Department of Homeland Security, the City Controller also requested an evaluation of the efforts being undertaken by the City to resolve peer review findings. The specific areas assessed during this performance audit included:

Summary of Results

The City has not established an appropriate organizational structure or effective mechanisms for coordinating emergency planning and disaster preparedness activities. Authorities are not well balanced, overall missions and priorities have not been established and communicated by officials through a comprehensive Citywide strategy, and resources to accomplish key objectives are not clearly understood. Changes are needed to ensure the City is effectively prepared.

Further, the condition of the City’s emergency plans, training programs and collaborations with external organizations does not adequately ensure that the City will have an effective response to emergencies or disasters. The audit found that emergency plans are outdated and incomplete; training is not approached strategically; corrective actions go unresolved for long periods; and collaboration with other government, private and non-profit entities needs strengthening. Because of the significance of the Department of Homeland Security grant programs in which the City participates, improvements are also needed in the administration and evaluation of key federal grant programs.

The audit found strengths with current operations. Recent changes in the leadership and structure of the Emergency Management Department are encouraging, with steps being taken to conduct internal assessments to improve the organization’s effectiveness. Similarly, the Mayor’s Office has recognized some of the weaknesses that have existed with UASI and SHSGP grant management, and has independently initiated improvements in FY 2007-08.

Key Findings

  The City has not articulated a strategic vision or developed a strategic plan for accomplishing critical emergency preparedness goals and objectives.

Strategic plans are tools that assist organizations with defining their missions, goals and objectives; approaches toward achieving goals and objectives; and, methods for measuring the success of a program. Such plans communicate goals and objectives to constituencies, develop a sense of ownership by responsible officials, and provide a mechanism whereby an organization can develop strategies for leveraging scarce resources in a cost effective manner. Like a budget, a strategic plan should be established and built upon each year so that it addresses the changing needs and priorities of the organization.

In Los Angeles, emergency planning and disaster preparedness priorities are not driven by a Citywide strategic vision or plan, but rather by the requirements of federal and State government grant programs, immediate concerns expressed by various mayors and city councils, regional collaborations, and other initiatives that originate at the departmental level. The City has published a Master Plan and departmental emergency plans. However, these plans are designed to ensure operational readiness and the coordination of departments and external partners during an emergency. They do not provide the key elements of a strategic plan, which is intended to define overarching program goals and strategies for success.

Further, the City does not take full advantage of opportunities to define emergency preparedness goals, objectives or strategies. For example, the annual Lake Arrowhead Conference focuses on training, collaboration and limited emergency planning and disaster preparedness gap analysis. While the Conference is also intended to produce some policy direction from the Mayor and define short-term emergency preparedness objectives, a review of documentation from past conferences indicates that such results have been limited.

  The current formal leadership structure of the EOB does not provide balanced authority or accountability for critical emergency preparedness functions. There is no formal role for the Fire Chief on the EOB; and, the EMD does not fulfill a top leadership role on the Board, or have the institutional authority to ensure consistent coordination of and cooperation from City departments.

Other than simple membership, there is no formal role for the Fire Chief on the EOB, even though the Fire Department would play a critical role in virtually every major emergency or disaster. In addition to his role as a member of the EOB, the Administrative Code charges the General Manager of the EMD with coordinating “the authorities, powers, duties, and responsibilities of the Emergency Operations Board and Organization.” However, the EMD does not fulfill a top leadership role on the EOB, nor does it have the institutional authority to ensure consistent coordination and cooperation from City departments on an ongoing basis.

The City of Los Angeles should explore alternatives for strengthening the formal authorities of the Fire Department and EMD through the EOB structure. One alternative would be to establish an Executive Committee of the EOB that would include the Police Chief, the Fire Chief and the General Manager of EMD. This group could be assigned specific authorities in the Administrative Code that would ensure a more balanced and strategic approach to emergency management in the City. For example, the Executive Committee could be made responsible for directing activities related to the development and maintenance of a strategic plan, evaluating staffing and resource allocation requests for emergency management services across all City departments, providing oversight and recommendations to the Mayor regarding UASI and other major homeland security and disaster assistance grant programs, and generally directing the emergency planning and disaster preparedness activities of the departments, in accordance with directives received from the Mayor and City Council.

  There is no up-to-date or complete inventory of all of the City’s emergency plans. In addition, emergency plans are not timely, and the content of such plans is not consistent or of high quality in all cases.

Emergency plans, if completed in a timely, clear, organized, and comprehensive manner, should serve as a critical and effective element of emergency management by defining the roles, responsibilities, and required actions by personnel and agencies during emergencies or disasters. The City of Los Angeles has many emergency preparedness plans with varying purposes and objectives, but many of these plans are not timely or up-to-date, have inconsistent plan content and quality, and have weaknesses relating to plan effectiveness.

For example, out of the 26 Departmental Plans reviewed for this audit, sixteen, or 62 percent, had not been updated for at least three years. Some of the Police Department plans that were on file at the Emergency Operations Center had not been revised since 1998, and one of the Fire Department plans had not been revised since 1992. Master Plan annexes, which are either disaster-specific (e.g., earthquake, tsunami) or functional (e.g., evacuation, care and shelter) plans that are intended to augment the City’s Emergency Operations Master Plan and Procedures, exhibited similar weaknesses. For example, 10, or 59%, of the Master Plan annexes had not been updated for over 10 years, and 6, or 35%, had not been revised since 1993. Further, eleven of the 26 departmental plans reviewed, or 42%, were non-compliant or inconsistent with the most recent EMD guidelines and standards. Not having timely and consistent emergency plans could result in inaccurate and confusing information during an emergency, which could negatively impact the City’s overall emergency and disaster preparedness and response.

In addition, a formal review of departmental emergency plan compliance with the standard elements of Continuation of Operations/Continuation of Government (COOP/COG) has not been completed, and almost all departmental emergency plans do not meet National Incident Management (NIMS) standards, which include critical elements that should be incorporated into existing emergency plans. When emergency plans do not comply with COOP/COG and NIMS standards, the overall effectiveness of the plans are limited, particularly with regards to ensuring the continuation of essential functions and maintenance of governmental institutions during emergencies. Further, by not complying with these standards, the City cannot ensure consistency when preparing for, responding to, or recovering from an emergency or disaster situation. For example, no departmental plan described resources that would be managed during an emergency event, nor did they include a comprehensive resource management protocol regarding mutual aid during exercises or actual events.

  Emergency preparedness exercises and training are not well coordinated or planned

Emergency exercises and training are integral parts of the City’s overall emergency preparedness efforts. City employees participate in a variety of emergency preparednessrelated exercises and training activities every year, but improved tracking, planning, and coordination are needed to ensure efficiency and effectiveness. For example, listings of emergency preparedness exercises and training are not always comprehensive and complete, making it difficult to assess whether the current exercises and training functions are duplicated or overlapping, and if specific gaps exist. Training and exercise activities are also not fully coordinated and the process for planning and prioritizing these activities has not been established. For example, the City chose to participate in a County sponsored tsunami response exercise during the period of this audit. However, after the first day of the three day exercise, the EMD General Manager determined that City departments were not prepared to participate since staff had not yet been fully trained on the recently adopted Tsunami Response Plan or the City’s new on-line emergency information sharing software (i.e., Web EOC). Rather than participating in exercises merely because the opportunity presents itself, a strong centralized process for developing and implementing a needs-based, comprehensive, and multi-year approach to fulfilling the City’s emergency preparedness exercise and training needs is necessary in order to ensure these efforts are effective.

  After Action Reports corrective actions are not tracked or systematically followed for implementation

The City does not have a systematic or consistent approach for tracking and following-up on actions needed to correct deficiencies identified through exercises and trainings. Because there is no mechanism for ensuring that corrective actions are fully implemented, the City does not always make the improvements that are necessary to effectively respond to or recover from large-scale emergencies or disasters.

After Action Reports (AARs) are required for training exercises to identify deficiencies during exercises and to document a plan for correcting such deficiencies. However, the City does not have formal mechanisms for ensuring that AARs and improvement plans are completed after every emergency exercise. There are no provisions in the Master Plan requiring the completion of AARs, or improvement plans for all types of exercises within specified time periods. As a result, AARs and improvement plans are not always completed after every emergency exercise.

Available AARs reviewed during this audit did not completely adhere to federal guidelines. For example, many AARs were missing critical required components, including formal improvement plans, intended to outline actions that the exercising jurisdiction plans to take, and list recommendations, specific actions, responsible parties for implementing recommendations, and target completion dates.

  Comprehensive and collaborative strategies have not been developed with external public- and private-sector entities

There are federal, State and local government mandates and initiatives that authorize how public officials must work collaboratively with each other, as well as with private, non-profit and individual community members to respond to significant emergency incidents. While there are numerous institutional barriers to effective and sustained emergency collaboration, a review of the City’s efforts reveals that these collaborations are not systematically identified, organized, interrelated or maintained; nor has an overall structure and ongoing commitment to regularly and systematically partner with outside organizations been developed. As a result, overlapping and duplicative efforts, as well as significant gaps exist.

For example, there are not formal agreements with the Greater Los Angeles American Red Cross, such as exist in other cities and counties, specifying City and Red Cross responsibilities in the event of an emergency or disaster. In addition, both the Fire Department and Department of Neighborhood Empowerment (in cooperation with EMD) have community training programs, and until very recently, the Police Department had a similar program. Yet, these programs are not well coordinated and in some cases duplicate one another. In addition to building effective collaborations, the City of Los Angeles should coordinate outreach and public education campaigns regarding emergency preparedness so that effectiveness can be maximized.

  The Homeland Security grant administration processes have inefficiencies that impact program timeliness and effectiveness

Administration of a grant as large and complex as those provided through the Urban Area Security Initiative (UASI) is technically demanding and time consuming. Nonetheless, the administrative processes associated with these grants should be conducted as efficiently as possible, while still providing sufficient controls over the authorization and expenditure of funds. Failure to do so may unreasonably delay the execution of the grant program and place significant grant resources at risk.

Changes implemented by HSPS have not yet resulted in the substantial improvement in grant administration, especially those which are required for grant acceptance on behalf of City departments. Other improvements could be implemented, and the Administrative Code could be revised to streamline the process without compromising the Council’s policy and oversight roles. For example, certain administrative processes presently performed by the Mayor’s Office could be assigned to departments and the grants ordinance could be modified to provide certain delegated authorities to the Mayor.

  The Emergency Management Department does not perform substantial Homeland Security grant monitoring or program evaluation functions

Although the Homeland Security grant policy function is appropriately located in the office of the Mayor, the program and fiscal management of these grants reveal fiscal, grant and program management weaknesses that have a negative impact on the efficient use of grant funding and achievement of grant program goals and objectives. The responsibility to monitor and evaluate the effectiveness of Homeland Security grant programs should be assigned to EMD, to ensure grant activities are fully integrated with the emergency management goals of the City, defined through a recommended strategic planning process.

  Mechanisms have not been developed for ensuring that Homeland Security grant activities can be sustained and cost impacts are known

Homeland Security grant applications have not required a match, but will likely be required in the future. However, the City does not presently calculate discretionary fund contributions that grant funded activities require. Therefore, the City cannot easily identify resources that could be provided as matching contributions or estimate the cost to maintain grant funded activities in the event funding decreases. No City department or office is clearly responsible for determining the current or future General Fund obligation implied by acceptance of these grant funds.

The CAO’s fiscal impact analysis of UASI funding has to date been limited to implications for funding within the grant period. Its reports enumerate and summarize current positions funded with grant funds, but do not provide a separate calculation of the City resources that will be necessary on a recurring yearly basis to sustain all grant funded activities, if UASI funds decline or if a matching requirement is required. Acceptance of these grant awards takes almost a year, which leaves little time for the CAO to conduct a full analysis of the fiscal impact beyond the grant period and inhibits the City Council from requiring that this analysis be conducted.

  Control procedures do not provide sufficient assurances that Emergency Operations Fund expenditures are consistent with intended purposes

The Emergency Operations Fund (EOF) budget provides specific resources to assist various City departments within the Emergency Operations Organization to prepare for, respond to, mitigate, or recover from local emergencies such as terrorist attacks, earthquakes, fires, and other disasters. Currently, City departments use the EOF as a source of funds for various types of emergency preparedness-related expenses, including travel, training, equipment items, public outreach, supplies, and contractual services. A review of EOF charges found that some items charged against this special fund may not meet the intended purpose of the fund, including food catering expenses for events, monthly cable service fees, and software renewal fees. Establishing and actively implementing EOF policies and procedures are necessary in order to ensure the appropriateness and accountability of all projects and efforts that are funded through the EOF. In addition, the City should ensure that a portion of the annual EOF balance is set-aside as contingency to be used during a disaster or an emergency situation, when emergency funds are most needed.

  Progress implementing recommendations from a 2006 National Peer Review of the City’s emergency planning has been slow or stalled in some cases

Although substantial progress has been made in some areas, the City has not successfully implemented many recommendations for improvement that were identified as a result of a substantial evaluation effort made in 2006. Recommendations have not been implemented for a variety of reasons, including lack of a strategic direction from City officials and clear authorities for EMD, weaknesses in centralized planning and management, an ineffective system for collaborating with external entities at the policy level, as well as other factors.

For example, the National Peer Review noted that plans do not incorporate private sector capabilities and resources into the City’s emergency response and recovery strategy. During interviews, EMD staff confirmed that there has been minimal work with the private sector in this regard. Further, information from the Business and Industry Council for Emergency Planning and Preparedness (BICEPP) demonstrated that there has been little progress toward identifying private sector resources that could be made available during an emergency. Other research conducted for this audit confirmed that limited efforts have been made to formally incorporate non-profit resources into the City’s response infrastructure. In one significant instance, the City has not entered into formal agreements with the Greater Los Angeles American Red Cross that define City and Red Cross responsibilities in the event of an emergency or disaster.

Review of Report

On June 23, 2008, a draft report was provided to the management of the Mayor’s Office of Homeland Security and Public Safety and the Emergency Management Department for review. Exit conferences were held with both departments on June 27, 2008 to discuss the contents of the report. The departments indicated general concurrence with the findings and recommendations. We considered the department’s comments before finalizing the report.

Harvey M. Rose Associates, LLC would like to thank the management and staff from the many departments that participated in this performance audit.

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