A Debris Management Handbook for State and Local DOTs and Departments of Public Works (2014)

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4Synopsis of Issues This chapter provides state and local DOTs and DPWs with guidance on how to plan for debris removal and disposal operations following any type of debris-generating event. The planning concepts presented in this chapter expand upon those found within previous debris planning guidance. Traditionally, guidance has suggested that a debris management plan should also address debris management operations. Experiences over the past decade have demonstrated that it is more effective to have a separate debris operations plan, in addition to a debris management plan. Similar to emergency management plans having functional and support annexes that delve into the operational aspects of emergencies, debris operational plans should be developed in conjunction with the management plans. These two debris plans together will provide state and local emergency managers, DOTs, and DPWs with a comprehensive planning approach that leads to more effective debris operations. This chapter draws a distinction between a debris management plan and a debris operations plan, while noting that both documents are necessary to effectively manage debris recovery after any type of event. This chapter also maps out the steps for developing the two planning documents. Target Audience • Local and regional DOT and DPW managers. • State agencies [DOT, General Services Administration (GSA), Department of Environmental Protection (DEP)/Department of Environmental Quality (DEQ)]. • Emergency management planners/emergency operations planners (EOPs). Why Is Planning for Debris Important? Debris removal is the critical starting point of both the disaster response and disaster recovery phases. The scope and scale of debris operations often catch communities by surprise; debris removal operations following a disaster can easily account for more than 40 percent of total disaster recovery costs. Communities need to be prepared to implement effective and efficient debris operations immediately following any debris-generating event, with no delays or hesitations. Pre-disaster debris planning efforts allow communities to identify gaps and shortfalls in advance of an event so those items may be addressed. The goal of a well-organized planning process and the resulting plans is to be better prepared to manage disaster-related debris in a more efficient manner. Effective management results in timely access to critical infrastructure and expediting of the recovery process. In addition, for federally-declared disasters, a sound and properly executed debris management plan may better position communities to take advantage of legislation and debris policies that provide supplemental funding for responsive and effective debris operations. C H A P T E R 2 Planning

Planning 5 Examples: Hurricane Ivan: When the storm hit in September 2004, the Escambia County, FL, government had a plan in place and stated that “time spent planning was time well spent.” The plan pre- identified contractors and sites for debris processing and removal. World Trade Center Attacks: On September 11, 2001, the City of New York had a debris plan in place and sites had been pre-identified through its planning process. While the scope and magnitude of the event far exceeded the City’s plan, having a plan in place and identified debris sites increased debris management capabilities. County Wildfires, 2003: A government did not have a debris management plan in place before this incident, which was a major program challenge. The County believes it could have saved time and been reimbursed by FEMA more easily if a plan had been in place. What Planning Documents Should Be Developed? The development of effective debris management plans has continually evolved, producing new programs and policies at all levels of government. Historically, debris management plans have enabled jurisdictions to establish roles and responsibilities of all parties associated with debris operations. They have also provided guidance and background for implementing those activities. Some debris management plans do very little, however, to provide guidance for operating effectively when responding to debris-generating events. The debris management plan may describe the most likely types of hazards a community faces, but it offers no suggestions when the actual event does not match the plan. The debris management plan may describe the total landfill capacity for a county with C&D debris, but it doesn’t tell a public works department how to determine staging areas when the debris is a mix of vegetation, C&D, household hazardous waste, white goods, etc. The debris management plan may outline staffing options available to a community after a disaster; however, it may not address a situation when much of the staff has been made unavailable; or how a large regional disaster will affect staffing through exist- ing memoranda of understanding (MOUs) or memoranda of agreement (MOAs). The lessons learned from debris-generating events indicate that debris plans need to consider two distinct and separate phases of debris—pre-disaster management and post-disaster operations. The debris management plan is a document based on anticipated identified threats, risks, vulnerabilities, capabilities, and resources. The management plan establishes the organizational structure (see Chapter 6 on operational structure and organization), roles and responsibilities, applicable policies (federal, state, and local), reporting processes, sequence of events, anticipated duties, and other key components. The debris management plan also includes the anticipated debris-specific issues based on the predicted disaster threats, used as a modeling example (see Chapter 3 on forecasting and estimating). The debris operational plan is a post-disaster guidance document that modifies the assumptions from the debris management plan and accounts for the specific criteria of a unique disaster event to adapt the debris response and recovery activities. Subsequent chapters will also provide more details on each of the phases of the debris management cycle, some of which should be considered as part of the operational planning process. What Is a Good Debris Management Plan? Planning for debris management prepares jurisdictions for the type and quantity of debris they should expect from a designated event (or events). This will allow officials to implement procedures and criteria that will help ensure their reimbursement requests are consistent with

6 A Debris Management Handbook for State and Local DOTs and Departments of Public Works existing local, state, and federal laws. A good plan also establishes an operating framework identifying key players and their responsibilities, approaches for clearing and removing debris, and strategies for disposal. It may also identify the need for additional resources and applicable points of coordination required to facilitate a smooth, efficient operation. The lessons learned from past events indicate, in order to protect people, debris removal planning should be based on a systematic approach, whereby every component is functional in itself and is coordinated into a cohesive working response. —FEMA Public Assistance (PA) Planning Workshop Instructor Guide (1) The purpose of a debris management plan is to establish partnering relationships through communications and pre-planning with individuals that have debris management responsibilities. It outlines the roles and responsibilities and provides policies and guidance for the removal and disposal of debris caused by debris-generating events. The debris management plan should include and address the following: • Situations and assumptions: – Clarify the types of debris-generating events to which the community is susceptible. – State any assumptions made in development of the plan. • Authorities—identify adopted plans, ordinances, etc., that authorize debris management activities. • Roles and Responsibilities: – Primary entities. – Support entities. – Political entities. • Organizational structure: – Identify individuals by position title rather than name when determining who will function in what position within a debris management organization. – Define specific position responsibilities. – Follow the Incident Command System (ICS), as outlined in Chapter 6. • Policies: – Private property demolition and debris removal policies. – Contracting and procurement policies. – Reimbursement policies. – Health and safety requirements. – Recycling requirements. – Environmental and permitting requirements, including historical preservation. – Local building condemnation policies following a disaster. • Public Information Plan: – Message – Development of public information announcements that may be required. – Distribution methodology: 77 Pre-event. 77 Post-event. What Is a Good Debris Operational Plan? The purpose of a debris operations plan is to identify required capabilities and unify them with the efforts of organizations into a comprehensive and effective approach. The plan estab- lishes the most efficient and cost-effective methods to resolve disaster debris removal staging, reduction, recycling, processing, and disposal issues. The debris operations plan establishes a

Planning 7 strategy for the debris operations that is flexible and can be adjusted depending on the variables of an actual event. The debris operations plan should include and address the following: • Debris Management Operational Assessment Base Data: – Identification of a “design event” on which the operational approach is based, while stating that the approach is flexible and scalable to address a wide variety of events of differing magnitudes. (Such an event should be a type considered as most likely to occur.) 77 Specifically identify issues and tasks that need to be evaluated and adjusted depending on the event. – Types of debris to be considered. – Debris estimate methods. – Identification of particularly susceptible areas and communities. – Debris zones. – Debris removal site priorities. – Debris hauling routes and traffic impacts. – Debris management sites. – Resources capabilities (how much debris can force account resources effectively manage). • Debris Management Strategy: – Resource requirements and capabilities 77 Force account. 77 Contractor: • Standby contracts. • Emergency contracting. • Debris operations to be outsourced. – Scheduling expectations, capabilities, and assumptions. – Clearance: 77 Coordination with emergency responders to clear roadways. 77 Clear priority roadways to promote traffic flow. 77 Establish priorities for both clearance and removal so all parties are aware. – Debris site selection, setup, operation, and closing: • Alternate sites (should be determined prior to an event). • Utilities availability. • Permitting requirements. • Testing requirements. • Debris management site (DMS) safety requirements. • Closing requirements. – Removal: 77 Curbside pickup. 77 Drop-off centers for the public: • Locations. • Operational information. • Staffing. 77 DMS(s). 77 Timeframes for removal—define how long operations will continue and communicate clearly to the public. 77 Private property debris removal. 77 Debris monitoring plan. – Reduction: 77 Methods: • None. • Chipping/grinding.

8 A Debris Management Handbook for State and Local DOTs and Departments of Public Works • Burning: 44 Air curtain operation. 44 Open burning. • Recycling. 77 Locations: • Curbside. • DMSs. • Landfill. – Disposal: 77 Landfill. 77 Recycling. 77 Landscaping. • Health and Safety Plan: – Pickup and removal operations. – Traffic control for debris operations. – Opening, operation, and closing of DMSs. • Documentation and Reimbursement: – Documentation and tracking: 77 Accounting codes. 77 Load tickets: • Paper. • Automated. – Force account time tracking. – Equipment tracking. • Final Closeout Checklist: – All eligible disaster debris removed to disposal. – All DMSs officially closed. – All documentation reviewed and submitted. – All appropriate agencies notified. – All known issues resolved. When Should Debris Plans Be Written? Ideally, debris management plans and debris operations plans should be written in a period of “peace time,” rather than during or right after an event. When developing plans, the process should be given priority. Making sure there is adequate time for coordination and input improves the understanding and expectations once an event occurs. The debris operations plan will also need to be reviewed and modified when a disaster event occurs, based on the conditions of the actual event. The plans should be reviewed annually and revised as appropriate to reflect changing conditions within a jurisdiction. In a geographical area that has a “typical” disaster cycle, such as hurricane season, planning should start as far in advance of that season as possible (almost immediately after the end of a season, if feasible). Who Should Be Involved in the Planning Process? Debris planning is typically initiated and facilitated by the department or agency responsible for debris. Generally this will be the DPW, department of solid waste management, or DOT. However, sometimes debris plans are written by the emergency management group within a

Planning 9 jurisdiction, in which case its contents and strategies must be coordinated with those responsible for implementing and executing the plans. One issue that can occur at times is that the actual event may not comply with the assumptions used in developing the plans. That is to be expected, and the plans should be developed with that realization. If the plans are properly written, it should be easy to modify the original assumptions in a short time to make them relevant and event specific. The planning process should include any internal or external department, agency, or organi- zation that would have either a primary or support role in the debris operation. Some examples of agencies that are often involved in debris management may include, but are not limited to: • DPW. • Department of Solid Waste. • Office of Emergency Management. • Electric utility and cellular telephone providers. • DOT. • Parks and Recreation. • Water/wastewater utility providers. • Public Information Office and local news media. • Department of Environmental Quality. • Land Use/Zoning Department. • Public Safety. • Fire and Rescue. • Historic Preservation. • Geographic Information System (GIS). For a debris plan to be effective, it must be approved by upper management personnel in the agencies, departments, or organizations that are identified in the plan as having directing or sup- porting roles in debris operations. How Should the Planning Process Be Performed? Currently, little substantive guidance on how to write debris management planning docu- ments exists outside of FEMA’s PA Pilot Program guidance from 2007. While the FEMA PA Pilot Program guidance is a good starting point, consistency among debris plans still varies greatly. As with other types of plans, a debris plan is often developed using a strict template, which limits its effectiveness as well as the ability to create customized strategies for unique situations. Other planning processes that have clear established guidance are outlined in documents such as the Comprehensive Planning Guide (CPG) 101 issued by FEMA (2). For consistency with other emergency planning documents, the process outlined in this chapter follows the CPG 101 guidance. Figure 2.1 depicts that planning process. While this planning process can be followed for both the debris management plan and the debris operations plan, it is important to note that the two plans also can be developed in tandem, given that information from the management plan will be a basis for the operational plan. Form a Collaborative Planning Team Planning is best performed by a team. By using a team, relationships can be built and expanded to help bring creativity and innovation to the planning process. Using a team or group approach helps organizations define the role they will play during an operation. Case studies and research reinforce this concept by pointing out that the common thread found in successful operations is that participating organizations have understood and accepted their roles. —FEMA CPG 101 v2 (2)

10 A Debris Management Handbook for State and Local DOTs and Departments of Public Works The agency responsible for debris management should recruit and establish a planning team. As previously mentioned, the planning team should consist of stakeholders who have a primary or secondary responsibility for debris. CPG 101 provides the following tips for convening a planning team: • Plan ahead. The planning team should receive sufficient notice about where and when the planning meetings will be held. If time permits, ask the team members to identify the time(s) and place(s) that will work for them. • Provide information about team expectations. Planners should explain why participating on the planning team is important to the participants’ agencies and to the community itself, showing the participants how their contributions will lead to more effective operations. In addition, budget and other project management concerns should be outlined early in the process. • Ask the senior elected or appointed official or designee to sign the meeting announcement. A directive from the executive office carries the authority of the senior official and sends a clear signal that the participants are expected to attend and that operational planning is important to the community. Understand the Situation To provide a reasonable basis for planning, a threat/hazard identification and risk assessment should be performed. For debris planning, this should focus on the types of events to which the state or local jurisdiction is vulnerable, what types of debris could be generated by those events, and what gaps presently exist in capabilities to effectively manage the debris generated. The analysis will help the planning team determine priorities, develop or compare courses of action, and inform decision making. It is important to note that many times states have state-declared disasters for events that do not meet the criteria for a federal declaration. In many instances, damages from an event are not sufficiently large for either a state or federal declaration, and the entity still has to move the debris. The planning team should consider the varying levels of events that could generate debris, whether large or small, declared or not declared, and consider how resources and coordination need to be scaled depending on the type of event. Figure 2.1. Steps in the planning process. (Source: FEMA CPG 101 V2) (2)

Planning 11 Determine Goals and Objectives Using information from the analysis, the planning team can determine the operational priorities, which establish how the hazard or threat would affect debris operations and what defines a successful outcome for the community. Once the operational priorities are established, goals and objectives can be developed. Goals and objectives should support the operational priorities and clearly indicate the desired result or end-state they set out to accomplish. This approach fosters a uniform effort and purpose among the primary and support groups and activities involved in implementing the plans. Goals should be broad, general statements that specify the intended solution to problems identified by the planning team. They indicate what is expected to be achieved to those involved in the operation. They also help identify when components of the operation are complete, and signify that the operation is successful. On the other hand, they could indicate when and where things went wrong or were challenging, and help pinpoint gaps and areas for improvement. Objectives are more specific and identifiable actions that must be accomplished during the operation, and lead to achievement of the operational goals. The responsible organizations need to translate these objectives into activities, implementing procedures, or operating procedures. The step of developing goals and objectives may bring to light more requirements that will need to be considered in the development of courses of action as well as the capability estimates. Example: Los Angeles County, CA (Northridge Earthquake) (3) Los Angeles County did not have a debris management plan in place prior to the 1994 earthquake. The County strived to recycle as much of the earthquake-generated debris as possible, so the government was required to create a plan retroactively. Los Angeles County was successful in accomplishing its recycling goal, due in part to a high level of participation and cooperation by residents. Plan Development Once priorities, goals, and objectives are determined, the planning team will need to develop and analyze what courses of actions should be taken. According to (and adapted from) CPG 101, developing the course of action will include the following: • Establishing a timeline—This step allows the planning team to identify when certain actions will occur, when critical decisions need to be made, and when resources will be needed. • Depicting a scenario—This scenario is based on the threat/hazard and risk assessment, and is simply meant as a reasonable foundation for planning, not an absolute for what will occur. This is where the scale and types of possible debris-generating events come into play. • Identifying and depicting decision points—This step establishes what decisions need to made and when for the operation to be most efficient and effective. • Identifying and depicting operational tasks: – What is the specific action? – Who is responsible for the action? – When should the action take place? – How long should the action take and how much time is actually available? – What has to happen before? – What happens after? – What resources does the person/entity need to perform the action? Once the requirements are determined, the planning team will need to identify (1) what resources are needed for the operation, and (2) what resources are available. Assignments should

12 A Debris Management Handbook for State and Local DOTs and Departments of Public Works not be based on availability; rather, assignments should be based on need. By tracking resource obligations and assignments, the planning team can identify resource shortfalls and develop solutions for filling those gaps, either through private contractors or other non-essential staff. It is important to note that resources do not just include required equipment and personnel, but also those facilities vital to the operation. The planning team should consider how individual hazards might affect all identified resources as well. Throughout this plan development phase, the planning team should keep a list of information and intelligence that is needed for them to make the most informed decisions. They should regularly identify information and intelligence needs and then set deadlines for receiving that information so as not to delay the planning process. A sample planning checklist can be found in Appendix A. Plan Preparation, Review, and Approval Process The planning team is now ready to draft the planning document. Adapted from CPG 101, the following is a list of helpful hints for writing any plan that will help ensure readers and users understand their content: • Keep the language simple and clear by writing in plain English. Summarize important infor- mation with checklists and visual aids, such as maps and flowcharts. • Avoid using jargon and minimize the use of acronyms. • Use short sentences and the active voice. Qualifiers and vague wording only add to confusion. • Provide enough detail to convey an easily understood plan that is actionable. The amount of detail a plan should provide depends on the target audience and the amount of certainty about the situation. • Format the plan and present its contents so that its readers can quickly find solutions and options. • Focus on providing mission guidance and not on discussing policy and regulations. Plans should provide guidance for carrying out common tasks, as well as enough insight into intent and vision so that responders can handle unexpected events. However, when writing a plan, “stay out of the weeds.” Procedural documents [e.g., standard operating procedures (SOPs)/ standard operating guidelines (SOGs)] should provide the fine details. • Ensure accessibility by developing tools and documents (e.g., print, electronic, video) so they can be easily converted to alternate formats. Once drafted, the planning team will need to initiate a review process. Planning team members can and should review the drafts, but outside, third-party reviewers should also be utilized. Expectations and a timeframe should be associated with the review. Comments and edits should then be evaluated and incorporated as appropriate. The planning team may choose to undergo more than one review cycle, but should keep in mind that at a certain point reviews become counter- productive, so the planning team should only do as many reviews as they feel will provide value. Final documents should then go through an established approval process prior to implemen- tation. Obtaining an official approval of the plans will validate their importance and establish an even higher expectation for implementation. Depending on which is the primary agency for debris, the agency head and/or state or local jurisdiction leadership should sign off on the plans. Plan Implementation and Maintenance To ensure all staff involved in the operations understand the coordination requirements and operational goals and objectives, the plans should be disseminated to all primary and support departments and agencies responsible for any part of the debris operation. These departments

Planning 13 and agencies should be required to train their staff on the plans. It would also be beneficial, and should be required, that the primary agency, in collaboration with the emergency management office, plan and conduct an exercise or series of exercises to further evaluate and validate the plans. Regardless of the level of detail planned for within the plans, each actual event will present different challenges. Immediately upon the notice of a possible event, or event at the onset, the operational stakeholders should conduct a quick review of the plans and determine what actions may need to be adjusted, added, or omitted based on the nature or scale of the event. An effective practice for planning is to review and revise plans after any event, exercise, or training. Tracking and discussing the effectiveness of the debris operation is important for improving the plans for the next event.