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Why question Reports? Municipal Analysis, Truth or Fiction?

The following is an analysis of manpower and system report relied upon by my local government. Where it was not a product of the current administration, it is still used. The data demonstrates the current reduction in is inadequate, City Officials continue to use it to resist increasing the current manpower even as the number of runs have increased every year. Without “context” from an experienced source it is very hard to decipher ambiguous reports. With over 25 years in the fire service and over 20 years as a fire service Instructor for the State of Michigan, I have provided this context for the betterment of my City. Fiscal responsibility includes proper Fire Department staffing to handle increasing loads. Taxpayer funds should be spent for strengthening municipal infrastructure, which is the concept of local taxation.

The following analysis shall be in bold type, while the actual documents are reprinted in non-bold font. Highlighted green sections of the document feature the focus of ICMA statements. I have not corrected the confusing grammar of the ICMA document, only reprinted its actual form.

Page – 2 Generalized Purpose of this organization

ICMA Consulting Services

The ICMA Consulting Services team helps communities solve critical problems by providing management consulting support to local (Governments. One of ICMA Consulting Services’ areas of expertise is public) safety services, which encompasses the following areas and beyond: organizational development, leadership and ethics, training, assessment of calls-for-service workload, staffing requirements analysis, design of standards and hiring guidelines for police and fire chief recruitment, police/fire consolidation, community-oriented policing, and city/county/regional mergers.

Remember these highlighted statements, as we shall return to this focus statement at the end of this report analysis.

Pages – 12, 19, 23, 24, 31, 33, Assessment and Planning 

Page 12 –

8. Conduct a comprehensive needs assessment with the development of a standard of cover (SOC) document.

Page 19 –

Commission on Fire Accreditation International (CFAI). Another highly influential group, the CFAI consists of representatives from the International Association of Fire Chiefs (IAFC) and ICMA. The CFAI and its accreditation process were designed to establish industry-wide performance measures for overall organizational performance. A jurisdiction’s use of these measures is purely voluntary. While a small fraction of fire departments across the nation have gone through the CFAI’s process and others are working toward that goal, most departments focus on the creation of a standards of cover (SOC) document (one of four items required for accreditation). The SOC concept has become so useful that the CFAI has expanded the original 44-page chapter of the

Accreditation manual which discusses the SOC into a 190+ page “how-to” self-assessment manual.

Page 23 – Just as the SOC document establishes policies for analyzing hazards and determining needs, so does the assessment tool of fire department accreditation.

Page 24 – There is a cost associated with the accreditation process conducted by the CFAI; however, a department can purchase the SOC manual and its accompanying self-assessment manual at a nominal fee of less than $200. Even if the department chooses not to pursue formal accreditation, it should consider using self-assessment reference materials as a blueprint for improving overall fire department administration and operations.

Page 31 – Assessment processes and tools used along the way are the SOC and a water-supply assessment. Involving various stakeholders and relying on the many information sources available are essential.

Page 32 – The SOC is defined by the CFAI as those adopted, written policies and procedures that establish the distribution and concentration of fixed and mobile resources of an organization. The flow chart in Figure 6 provides the sequence of events for community risk analysis, which then leads to creating the SOC.

Page 33 – The development of the SOC is no easy task; however, initiating this process is extremely important. To form the basis for the SOC, risk assessment, concentration, distribution, and elements of time are consciously evaluated and service level objectives established based upon the jurisdiction’s desired service level.

This is interesting only in that, the cost of this report was in excess of $75,000.00USD and yet they seem to spend considerable time on “but-wait-there’s-more” advertising for an additional $200.00USD manual?


Page 17 – Policies and Procedures

1. Policies and Procedures Policy statements set forth the manner in which an agency intends to exercise discretion.

2. The Royal Oak Fire Department has established rules and regulations of conduct that delineate in a clear, understandable fashion the expectations of its members. The document, however, does not indicate a revision date. Administrative and general orders handed down by the fire chief, by definition address corrections or advise members to refrain from a certain action. Since organizations are dynamic by nature, it is unusual that these types of orders have not been generated within the ROFD.

This is the first statement regarding the fact that Fire Departments are dynamic, ever changing organizations that require frequent re-analysis to maintain a sustainable future. Hence manpower requirements undergo change whenever expansion changes are made and services are increased. Since specialty Teams have been added, one would assume manpower improvements. None have been made. Also, by definition, the ICMA is incorrect. A dynamic system affects changing operational orders but rarely changes to rules and regulations of conduct.

Page 18 and 19 – Assessment and Planning

Deciding how many emergency response resources to deploy, and where, is not an exact science. The final decision on a deployment model is based on a combination of risk analysis, professional judgment, and the willingness to accept more or less risk. Accepting more risk generally means that fewer resources are deployed, though deploying more resources is no guarantee that loss will be less, especially in the short term. Many sources of information are available for use in evaluating and analyzing public fire protection. The following resources can be referenced by city administrators and elected officials to help in the decision-making process.

Page 25 – Community Risk Analysis

Defined level of EMS expected, and the department’s ability to provide this level.

ICMA confirms deployment of resources should be made by risk assessment, professional judgement, and the acceptance of risk, this level should be evenly balanced. As run (load) numbers increase, less risk is accomplished by manpower increases. None have been made.

Page 18 and 19 – B. Assessment and Planning

National Fire Protection Association (NFPA). The NFPA is an international, nonprofit organization dedicated to reducing the worldwide burden of fire and other hazards on the quality of life by developing and advocating scientifically based consensus codes and standards, research, training, and education. It is important to note that not all NFPA standards are scientifically based. For example, NFPA 1710 “Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments, 2010 Edition is not based on scientific research. Rather, it was put into place by a majority vote of a committee, and reflects their experience and opinions.

There is no published information on the expected reductions in losses or injuries as a result of increased staffing and only a little information on the effect of increased response times. Even though it was formulated largely on the basis of expert opinions and task sequencing (what must be done and how many people it takes to do it) rather than research, NFPA 1710 has become the de facto benchmark for the emergency response community. Fire Operations Analysis and Data Analysis Report, Royal Oak, Michigan 19 However, the NFPA standard has not been embraced by some groups, including ICMA.

The NFPA recommendations are standards and guidelines developed by committees of chief officers, volunteer representatives, union officials, and industry representatives. Although the NFPA’s standards are not legally binding, they are often codified into local ordinances. It is important

therefore to consider NFPA standards whether or not they are adopted locally. They remain a widely used criterion for evaluating different levels of fire and emergency service organizations.

ICMA confirms that decision making should be made on professional judgement, and experienced opinions. Since the NFPA is the de facto benchmark for the emergency response community, and recognized why is it not embraced by ICMA? These standards have been ignored when they should have been accepted.

Commission on Fire Accreditation International (CFAI). Another highly influential group, the CFAI consists of representatives from the International Association of Fire Chiefs (IAFC) and ICMA. The CFAI and its accreditation process were designed to establish industry-wide performance measures for overall organizational performance. A jurisdiction’s use of these measures is purely voluntary. While a small fraction of fire departments across the nation have gone through the CFAI’s accreditation process and others are working toward that goal, most departments focus on the creation of a standards of cover (SOC) document (one of four items required for accreditation). The SOC concept has become so useful that the CFAI has expanded the original 44-page chapter of the accreditation manual which discusses the SOC into a 190+ page “how-to” self-assessment manual.

The CFAI does not make many explicit recommendations on standards for fire/EMS departments to adopt. Rather, it encourages a thorough

1] Assessment of risks in the community,

2] Public expectations regarding fire protection, and

3] An examination of the resources needed to meet expectations given the risks.

The creation of written standards should be based on that assessment. Part of the methodology for setting standards includes looking at what similar communities are doing.

Risk assessment, public expectation, and resource examination all are influenced in a positive direction by balanced manpower.

Figure 13, on page 56 clearly demonstrates the assessment of RISK is evenly balanced from ICMA station location data. Public expectations are of a balanced response capability; therefore resources for these responses need to be in “PARITY” from station-to-station across the City. With R-93 out-of-service 70% of the time, balance is not achieved and risk increases.

Page – 20 Interjurisdictional Comparisons.

Comparisons between departments that are similar in size, scope, and complexity and that offer the same range of services are important for assessing why one department falls below or above the average. Even though each community can be quite different with regard to demographics, population density, hazards, and environment, to name a few comparable factors, comparisons are still useful in raising questions related to system performance. This form of benchmarking will be discussed later in the report.

Second, because fire is not the only risk faced by a community, asset information can be used in the development and revision of disaster plans.


Page 34, 41 – Risk Outcome Models

NFPA 1720 recommends that these objectives be established to include specific time objectives for each major service component²that is, fire suppression, EMS, special operations²and objectives for the percentage of responses that meet the time objectives.

Page 41, 42, and 43 – Program Logic and Benchmarking

For example, stating that the ROFD’s “response time goal” is to reduce response time is a fine goal. However, an effective measure for this goal would be the percentage of time the department responds to fire incidents in five minutes or less. Another example of a qualitative goal statement might be to “control fire spread upon arrival”. The department could instead use the following measure: the percentage of fires that did not spread beyond the area of origin after arrival of the fire department.

The ROFD collects typical fire department data, such as response times, total inspections, total investigations, and response to structure fires and EMS calls by type. These statistics, although reflective of typical workload measures seen among fire service organizations today, should link department goals to specific target rates or percentages if they are to be used to justify budget requests to city officials.

Recommendation #10: Develop performance measures for each service delivery area within the department.

The ICMA states a reasonable goal in response to fire runs is fewer than five (5) minutes (or less). Therefore; any target rate above this level in time should trigger risk reduction through increased accessibility by equal balanced manpower, this has not been addressed.

Page 42 and 43 –

Benchmarking is the search for practices that lead to superior performance. Basically, it involves comparing performance across organizations to measures one’s own achievements and identify ways to improve. How a department is doing in comparison with last year is interesting, but not as interesting as how it is doing in comparison with national standards or with others in the same field. Unfortunately, most comparisons in the public sector focus on resources rather than on performance. Whether initiated by counterpart agencies or mandated by some higher level of authority, the benchmarking process usually proceeds through the following steps:

1] Identify the measures to be used-what is to be measured and what those measures will be.

2] Develop precise definitions of the operational indicators to be used by all participants, along with clear guidelines for implementing them and uniform procedures for collecting and processing the data and computing the measures.

3] Collect and report the data on a periodic, often annual, basis.

4] Use the comparative data to assess the performance of a particular agency or program, set targets for particular entities (or more general standards for the field at large), or identify star performers and industry leaders and investigate leading-edge practices, as appropriate.

There are challenges in the process that involve availability of data, reliability of data, reliability of comparative data, and variation in operating conditions. These factors should not, however, deter an agency from embarking upon this worthwhile endeavor as a means of improving performance.

The most common resource comparisons in the fire service are per capita costs, the number of firefighters per 1,000 populations, and the number of firefighters assigned to each vehicle. These data are of no value in measuring performance. A primary difference between comparative resource analysis and benchmarking is the extent to which the latter focuses on methods for improving performance. Benchmarking seeks to identify best practices and then implement those practices to enhance performance.

Recommendation #11: Identify benchmarking partners and develop a process for exchanging information based on a standard methodology.

Benchmarking based on increased practices as opposed to standards for manpower/vehicles is a demonstration of attempting more with less; this eventually increases response time, risk, and liability.

Page 52, 53, and 54 – Response Times

ICMA data analysis observations for Royal Oak for the one year period we studied are as follows:

The average response time for EMS calls was 6.1 minutes and the 90th percentile response time was 8.6 minutes.

According to NFPA response time standards, combined alarm handling, turnout time, and travel time for fire and special operations response should be six minutes or less with the department establishing a performance objective of not less than 90 percent for the achievement of each turnout 22 NFPA 1221, Standard for the Installation, Maintenance, and Use of Emergency Services Communications Systems. Based on the above data, travel times within the city are excellent, beating the standard. This is indicative of good station location. However each community should establish its own response/travel time standard based on several factors. Some of these are

(1) The use of historical fire and EMS response data,

(2) Demand for service, and

(3) The level of care that the community wants to provide and level of care that the community can afford.

Recommendation #15: Determine reasons for response time deficiencies and develop plan for problem resolution.

This data demonstrates the need to place R-93 back in service to lower response time to the proper NFPA standard. New data (included below) shows a deviance away from this standard. The correct solution is to restore this manpower to decrease response time and reduce municipal risk. By restoring R-93 to operational status 100% of the time you increase lifesaving to the proper level.


Over 4200 of these runs are EMS runs to the citizens and are monthly averages as follows for 2018;

Station #3                                         Station #2 to #3 area 70% of time

January 2018 – 5.26                           January 2018 – 8.83

February 2018 – 5.52                        February 2018 – 8.98

March 2018 – 5.34                            March 2018 – 8.23

April 2018 – 5.20                               April 2018 – 3.99

May 2018 – 5.29                                May 2018 – 3.18

June 2018 – 5.19                                June 2018 – 9.41

July 2018 – 5.65                                 July 2018 – 3.90

August 2018 – 5.15                           August 2018 – 4.12

September 2018 – 5.76                     September 2018 – 4.13

October 2018 – 5.77                         October 2018 – 5.67

November 2018 – 5.79                     November 2018 – 5.20

December 2018 – 5.89                      December 2018 – 4.88

Lastly recorded, Station #1 generated a small number of runs to this area at 6.20 minutes per run. This was calculated as an annual time.

It is not recorded but important to note, that 70% of these run times are Engine arrivals. Advanced EMS or transport arrived at a LATER unrecorded time placing citizens at further risk.

Page 63 – Service Delivery Alternative

Under EMS privatization, a private provider is responsible for all or part of the paramedic function. Local governments are usually legally responsible for EMS, and some governments fulfill this duty by providing the service themselves, usually as part of their fire departments. A city interested in privatization may choose to contract the entire paramedic function to a private ambulance company or implement a public-private partnership. A common arrangement is to contract with a private provider for patient transport and rely on the fire department for first response.

ROFD and its station locations are ideally suited to deliver BLS service; however, providing Advanced Life Support services has not proven cost effective or efficient. ALS services could be contracted out to one of three local ambulance companies within the surrounding area. This would enable the department to cut operating cost while continuing the provision of a valued service to the community. All paramedic positions within the department would be eliminated, thereby achieving a reduction in force and ambulances and equipment would be sold.

Recommendation #18: Consider contracting with a private ambulance company for ALS services and eliminate paramedic positions.

Return to the initial ICMA mission statement, where we started, this demonstrates that the ICMA group was unable to comprehend the basic ROFD structure, in which paramedics also serve as firefighters during suppression responses. This raises serious concern over the

understanding of the ICMAs’ area of expertise in public safety services.

In conclusion; “Best Practices” refers to a system where long term expectations must be chosen to implement the future continuation of your desired operation. In this situation, the removal of manpower resulting in R-93 being out-of-service 70% of the year, falls below this concept and risks operational failure to our citizens. Restore this manpower.

As run times increase so does risk. There is a clear picture correlating reduced manpower & vehicles in-service to increased run times.

Finally; when an organization evaluates a report provided from an outside source it cannot expect to cover all elements of your organization. However, it should be able to conclude basic solutions using clear and non-ambiguous ideas. The ICMA group has failed to understand basic ideas of how an emergency department operates. Many providers of these reports attempt to please the customer rather than expose the reality of running an organization.

The concept of these reports is that they are frequently using a wrong system. The goal is not to shape the question to achieve the customers’ mandates, but to expose the truth of the “cost of doing business” in the emergency response world. You cannot do “more with less” without sacrificing the very goal you are trying to achieve. What community will you end up with? A strong foundation to build on? Or a liquid cash base manipulated by an unstable future market? Choose wisely, to reduce risk.

Consider the source when evaluating results oriented reports on your Department. Realize their agenda may NOT be in line with yours.



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