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COML redux—The training begins

Written by Dan Hawkins

In the May 2007 edition of this column, we shared news of a Department of Homeland Security (DHS) initiative to develop training for a key position within the Incident Command System—that of the communications unit leader. In its FY05 Homeland Security grant program, DHS had mandated that all Urban Area Security Initiative regions and at least one metropolitan area in every state develop Tactical Interoperable Communications Plans (TICPs). It further required grantees to ensure that sufficient personnel were trained as communications unit leaders (COMLs) to carry out the plans.

The rub with this grant requirement was that the only existing training at the time was under the auspices of the National Wildfire Coordinating Group and was not considered wholly complete for the urban, all-hazards environment addressed by these plans. Few urban areas could field train COMLs, a fact that was highlighted two years later in a DHS scorecard of TICP regions issued in January 2007. Only 12 of the 75 regions were able to fulfill responsibilities of the position without difficulty during TICP validation exercises.

COML Development

The DHS Office of Interoperability and Compatibility (OIC), a unit of the department’s Science and Technology Directorate, kicked off a project that same month to develop all-hazards COML training. The SAFECOM Program was wholly at the time an OIC responsibility, and its practitioner-led approach guided development of the training. SEARCH, the National Consortium for Justice Information and Statistics, carried out the project with a working group of practitioners from across the country, course pilots in Los Angeles County, and trainer classes in Las Vegas and Atlanta. The developmental project formally concluded in July 2007.

At the time of our previous column on the topic, the first COML training pilot was about to be conducted and the DHS Office of Emergency Communications (OEC), a unit of the National Protection and Programs Directorate, was being made operational. Over the year that followed, OIC continued its sponsorship of course development and support of the COML Working Group. The two sister offices collaborated heavily during this period as primary elements of SAFECOM moved from OIC to the newly formed OEC.

A flurry of activity occurred between February and May of 2008, solidifying course materials, establishing qualifications for COML trainees and instructors, obtaining National Incident Management System (NIMS) certification of compliance, and planning inaugural classes. Some minor content changes were made, but the course remains 24 hours of instructor-led training, including exercises, quizzes, and a final exam.

Typing the All-Hazards COML

Under NIMS, resources are “typed” according to capabilities. Resource and incident typing are related but not wholly synonymous. Incident complexity and resource demands determine what type of incident it is, with Type 1 being the most complex and Type 5 being the simplest.

The COML Working Group had recommended in April 2007 that the course under development be targeted for training of people to serve during Type 3 incidents. It concluded that Type 4 and 5 incidents are rarely of a complexity requiring specific delegation of COML responsibilities. That is, the function is carried out through organizationally superior positions through standing procedures. Type 3 marks the threshold when most ICS command and general staff positions are filled and incidents move into multiple operational periods.

The Working Group felt that the Tactical Interoperable Communi-cations Plans were ostensibly targeted toward this level of incident, thus recommended that the course serve to develop Type 3 all-hazards COMLs.

Training Begins

The Office of Emergency Communications hosted two COML classes in the Seattle area in late May and June of this year. OIC provided trainers and worked to incorporate both members of the COML Working Group and people participating in the 2007 developmental project. OEC work in the Seattle region in preparation for the 2010 Winter Olympics served as the catalyst for these pivotal classes. The classes also effectively served as the handoff of the all-hazards Type 3 COML course from development to production, from OIC to OEC. The agencies worked together commendably throughout to see this process through.

The result was that 46 people from across the country were trained as COMLs in Seattle. The need to bootstrap subsequent training nationwide by establishing qualified trainers was apparent long beforehand. The Working Group had recommended earlier this spring that people with all-hazards Type 3 COML and instructor qualifications be required to serve as adjuncts under OEC-established instructors for at least one class. The Seattle classes provided an opportunity for members of the Working Group and attendees of the 2007 train-the-trainer classes with suitable credentials to serve as adjunct instructors, thus further bootstrapping the initial trainer cadre.

Enter the NECP

The Federal Fiscal Year 2007 appropriations bill that gave birth to OEC also directed DHS to submit a National Emergency Communications Plan this past summer. OEC engaged stakeholders through SAFECOM and its federal partners to develop the strategy-level plan. High among the needs identified by practitioners was the availability of COML training nationwide. Among other initiatives inherited by OEC when it became operational in early 2007 was development of Statewide Communications Interoperability Plans (SCIPs), a grant funding requirement of the states. As the NECP was being developed, it became further apparent through the SCIPs that COML training was a high priority of many.

The NECP describes in brief actions taken up until its July 2008 release for development of COML training. To further those efforts and meet identified needs, it establishes under its Objective 5, “Emergency Responder Skills and Capabilities,” Initiative 5.1, “Develop and implement national training programs and certification processes.”

Recommended 12-month milestones for NECP Initiative 5.1 include:
• Establishment of a national level training program and certification processes for COMLs and other positions;
• Finalization and publication of ICS Communications Unit resource definitions (personnel and equipment);
• And development of a nationwide interoperability channel usage guide and to ensure that a shared channel training curriculum and courseware are available.

Recommended 18-month milestones include:
• Development and use of standardized training and credentialing for COML and other ICS Communications Unit positions nationwide;
• And establishment of a certification process for other emergency communications users and providers, including COMT, dispatchers, and emergency response providers.

National Rollout

OEC has since undertaken an aggressive plan to roll out COML training both in support of NECP initiatives and through its technical assistance programs serving DHS grantees. It has established a multi-phase project to provide upwards of 50 classes covering all geographic areas of the country. The length of the project and number of classes will depend on response, but it is anticipated that several classes will be held in each Federal Emergency Management Agency (FEMA) geographic region.

The project also recognizes NIMS guidance that the states and territories are the primary authorities for credentialing people to serve in most ICS positions, including Type 3 all-hazards COMLs. The OEC’s role in providing training over the longer term will depend on how extensively states develop their own programs—if not for initial development of the capability, then for sustaining it. For example, the state of California has planned to dedicate a sizeable portion of its Public Safety Interoperable Communications (PSIC) grant money to support statewide COML training. It is yet to be determined how, or even if, other states will similarly pick up the initiative.

Two classes were held in conjunction with the APCO International annual conference in August, providing training to 57 people. The first classes to be officially considered part of the national rollout were held in Houston, TX and Columbus, OH, during the latter half of August. By the publication of this column, 11 others will have been held across the country, from Honolulu to Hartford, providing training for more than 400 people since May 2008.

All classes have been held in cooperation with the host states. Because demand is so widespread, each hosting state has been limited to 10 guaranteed seats in a class, with 20 being left open for others. Due to limited notice of classes during this first phase, the hosting state (or region in the case of the National Capital) have in practice have had more available to them.

While some grumbling has been heard about how available the course has been, the reality is that in nearly four years since the FY05 grant requirement for trained COMLs was released, demand for the training has swelled. DHS was able to roll out this first phase of training with little advertisement simply to meet known, pent-up demand. Subsequent phases will be more broadly announced. OEC will continue to address requests from DHS grantees for technical assistance in the form of COML training through this same program.

The best source for current COML training information, training schedule, and points of contact is through the SAFECOM Program “Current Projects” Web site (www.safecomprogram.gov).

It’s Official

During the writing of this column, DHS released Information Bulletin No. 294, on “National Incident Management System-Compliant All-Hazards Type III Communications Unit Training.” In addition to listing classes that will have been held by our column publication date, it announces that 10 classes will be held at undetermined locations across the country during the second phase of the national initiative between November 2008 and February 2009. It is expected that essentially all will be held during January and February 2009 to avoid traditional holiday season conflicts. It is not announced, but expected, that subsequent training will be conducted throughout 2009.

Perhaps most important, the information bulletin describes officially DHS’s expectation of what the states are responsible for, including:
• Identifying suitable COML candidates;
• Identifying suitable COML trainer candidates;
• And developing processes for COML credentialing.

At this point, OEC is providing certification of training to those who have successfully completed its classes. It has recommended, however, additional requirements for credentialing to perform in the role, including experience. Information on course prerequisites is available on the SAFECOM Web site, as are these further recommended credentials detailed in the “All-Hazards ICS Communications Unit Leader Task Book.”

Details of the trainer program are still being worked out. DHS will host several trainer classes in cooperation with stakeholders in 2009 to establish state-level abilities to sustain COML training.

ICS Comm Unit Leaders Still Needed

This column detailed a year and a half ago the need for COMLs nationwide. There is even greater need now in face of growing recognition of the COML’s role in communications operability and interoperability during emergencies. Through DHS’s initiative, more than 1,000 people will have been trained nationwide to serve in the role by the end of next year.

Emergency response is essentially a local responsibility in the United States, with some contribution by state agencies, and a lesser share by federal agencies. Likewise, the effort to support key Incident Command System positions during the vast majority of incidents falls to local jurisdictions. Homeland Security grant funding, as emergency management program funding before 9/11, has flowed through the states. The state administering agencies are consequently key to consistency across local jurisdictions in use of NIMS and its Incident Command System. Their decisions will similarly determine how well incident communications are managed through support for the COML position. 

Dan Hawkins is the director of public safety programs for SEARCH, the National Consortium for Justice Information and Statistics. He is author of “Communications Interoperability: A Guide for Interagency Communications Projects,” published by the USDOJ Office of Community Oriented Policing Services (COPS) and jointly sponsored by the DHS SAFECOM program.

Published in Public Safety IT, Nov/Dec 2008

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