The Emergency Response Plan- Alone It’s Not Enough by Kate Novick, P.E., C.S.P.

The Emergency Response Plan is something that most, if not all, water and wastewater utilities utilize to comply with industry standards and regulatory requirements. However, these plans could have utility far beyond compliance. Recognizing the growing difficulty to maintain service in the face of a long list of potential emergencies spanning from technological breaks to extreme weather to cyber events, more and more water and wastewater utilities are transforming their old Emergency Response Plans into something more. It is now becoming part of an emergency preparedness and response program that innovatively uses risk management, planning, training, and exercises to protect the utility mission from major emergencies that threaten to disrupt operations.

In my career working in many different sectors including government, healthcare, industrial manufacturing, food and beverage, and utilities, nowhere have I encountered professionals who work more tirelessly to maintain essential services in their communities and who are more dedicated than in the water and wastewater sector. The critical mission of water and wastewater is so clear and shared that it reverberates throughout the industry with a call to do what is right for the community now and in the future.

With this culture, maintaining our service even during times of emergencies can feel crushing as already we do so much with so little, battle aging infrastructure, cyber threats, budget cuts for some, and changing weather patterns that make it more difficult just to maintain our existing levels of service. As a result, we can no longer afford to have emergency plans that are not both: (1) compliant with standards and requirements, and (2) effective in a major emergency.

The Status Quo is No Longer Enough: Often when a new plan is drafted or an old plan is updated, what typically happens is this: first, we go to the latest templates. Then, section by section, we fill in and update the plan, pausing when we need information we don’t yet have, and then we speak with this expert, that manager, and the administrative assistant down the hall and continue until the plan is updated and complete. Then we share the draft with others who review it and offer feedback and eventually, after we incorporate their feedback, they offer their approval for the plan. It is then printed and kept enclosed in a binder and placed in an easy-to-access location or multiple locations. We also keep it on the network drive in a location where we or the next person responsible for the plan can easily find it.

Then we check “yes” to the box when asked, “Do you have an up-to-date Emergency Response Plan at your utility?” This is where we fall short because we think we are done. Early in my career, that’s what I did too because I didn’t know better. Over time, beyond the ubiquitous emergency contacts list which is always helpful, you will find that this process described above alone doesn’t produce an effective and useful plan.

Even with the best intentions, the plan may satisfy requirements but serve no further purpose. This happens when we (1) lack the time or capability to apply adequate contemplation and dialogue with others about the real needs of our utility; (2) lack the experience of what can catastrophically go wrong that may impact our utility; and/or (3) do not know the technically correct way to prepare for emergencies. To counteract all three of these conditions, the planning process should begin by asking a far more important question which is this: “How and why do we plan to respond to the needs of our time?” We must step outside of our comfort zone to find answers.

Standard Practices are Shifting: More and more utilities are testing their plans using tabletop exercises and drills and are performing risk assessments to direct the focus of their Emergency Response Plans. Utilities are also mitigating potential hazards and threats that could reasonably be expected to impact the utility. Utility leaders and managers are meeting with their response partners and talking shop and the results are rewarding and promising.

In business literature, there is the concept called “disrupt, or be disrupted.” Even though the concept is based on taking market share from competitors, the concept is fundamentally based on the question: “how to survive in a world of disruption.” This concept is apt for how water and wastewater utilities are using innovation and proven strategies to improve emergency preparedness. Adopting this concept may lead a utility to establish backup plans for its most critical functions, and backup plans for the backup plans. This is called “two-deep.” The utility may then investigate whether all their backup plans could share a single point of failure. For example, if all the backup plans are at risk of failing during an extreme flood, and an extreme flood could reasonably be expected to impact the utility, then it would be beneficial to innovate another backup plan that does not fail during an extreme flood.

The fully-realized Emergency Response Plan, or program as described above, arises out of our low points working tirelessly to maintain essential services to communities. It also arises out of recognizing the vulnerabilities of our utilities and all the failures- the failures of the systems we manage; and the failures we hear about from our peers. For example, in the City of Danbury, CT in April 2018, tens of thousands of residents plus local businesses, schools, nursing homes and a hospital were without water for 48 hours due to the failure of a valve. The city lost several million gallons of water. According to news reports, the replacement valve needed to be special ordered from Buffalo, NY. Let’s face it, when an emergency like this strikes at one of our peer utilities, a part of us knows that it could have happened to us.

I have found in my 20 years of developing emergency preparedness programs at hundreds of facilities, that although it’s uncomfortable, beginning a plan in full recognition of all emergency events that could reasonably be expected to happen, we begin in a place that offers the possibility for a utility to significantly transform their level of preparedness into greater strength and resilience. It’s the difference between having a plan and then blowing like a leaf in the wind during a major emergency, and having a plan designed with skill and insight that enables the utility to reduce losses, reduce duration of the emergency, and mitigate and prevent some things that can go wrong.

The fully-realized plan is no longer imprisoned in a 3-ring binder. Now it is leaping out and into our staff who establish preventative precautions ahead of time through their insight and then take skillful actions during an emergency. This is called a “culture of preparedness.”

Assign a Leadership Team to Look at Risks: If your utility does not already have a leadership team questioning and examining what could happen and threaten your utility’s mission, assign the role to your leadership team. Once assigned, that role can initiate protections against loss of life, loss of property, loss of revenue and economic stability, and damage to your utility’s reputation. Activating this role is significant and necessary to adequately respond to the needs of our time.

When we work on Emergency Response Plans, it is our responsibility to not just go through the basic template process but to also counteract our default reaction that minimizes what could go wrong. We need to go into deep inquiry. We can utilize scientific data like annual rainfall and temperature data; utilize valid resources like FEMA Flood Maps; investigate our neighboring facilities and identify what chemicals and quantities are stored there; review our regional and state hazard mitigation plans and Threat Hazard Identification and Risk Assessment (THIRA) report; and seek other data to clarify exactly what are the risks that could impact our facility, operations, and staff and other resources. We can meet with our local fire and police departments and local Emergency Managers and listen to their perspectives on the potential risks. It is an ongoing process of perseverance with one goal: protecting our utility’s mission.

Planning Resources Are Available: The following resources contains more information to help water and wastewater utilities plan for emergencies: ANSI/AWWA G440-17 Standard on Emergency Preparedness Practices; the AWWA M19, Emergency Planning for Water and Wastewater Utilities published in 2018; and the AWWA and Water/Wastewater Agency Response Network’s Hurricanes Harvey and Irma After-Action Report also published in 2018. One helpful resource for water and wastewater utility personnel to prevent and prepare for cyber emergencies is AWWA G430-14 Standard on Security Practices for Operation and Management. Also FEMA’s is a good resource for everyone.

Last Words: Emergency response planning is not just a box to check. It’s a real opportunity to dig deep and identify actual risks to your utility. With this knowledge, improved actions are not only possible, they can enable us to reduce losses, reduce the duration of an emergency, and mitigate and prevent some things that can go wrong during an emergency.

Kate Novick is the Managing Director of Gradient Planning LLC in Middletown, CT. Contact her at or 860-402-6597.

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