Published September 14, 2026. For current incident information, use the official sources linked in this article.
A federal court recently issued an interesting ruling involving FEMA and the agency's staffing levels.
On September 11, U.S. District Judge Susan Illston ruled that the Department of Homeland Security acted unlawfully when it took actions aimed at significantly reducing FEMA's workforce, including directing the agency toward a 50% staffing reduction. The court found that the staffing decision was arbitrary and capricious and that DHS had exceeded its authority in taking control of certain FEMA personnel decisions.
The ruling is obviously significant from a legal and federal workforce perspective. But there is also an emergency management question underneath it that is worth considering:
How much does staffing capacity matter to an organization's ability to actually execute its emergency management mission?
The answer seems pretty straightforward. A lot.
Plans Don't Execute Themselves
Emergency management produces a lot of plans.
Emergency operations plans. Continuity plans. Recovery plans. Hazard mitigation plans. Evacuation plans. Annexes, checklists and procedures.
All of those things are important. But having a good plan sitting on a server doesn't mean an organization is prepared to execute it.
People execute plans.
During an incident, someone has to recognize the problem, activate the organization, establish priorities, communicate with partners, track resources, coordinate operations and make decisions with incomplete information.
That requires trained people who understand both their own responsibilities and how their organization works with everyone else.
The Part of Staffing That Isn't Obvious
Reducing staff doesn't necessarily mean simply having fewer people available to answer the phone.
Over time, staffing changes can affect institutional knowledge.
An experienced emergency manager may know which neighboring jurisdiction can provide a particular resource, who needs to be contacted during an activation, which vendor actually performs well under pressure, or why a particular procedure exists in the first place.
Some of that information will never be found in a written plan.
It's learned through experience.
That is one reason turnover can be particularly challenging in emergency management. You can replace a position on an organizational chart fairly quickly. Replacing years of experience and relationships is much harder.
Recent Government Accountability Office reporting on FEMA also identified loss of institutional knowledge and experienced personnel as a concern following significant workforce departures.
Exercises Matter More When Staffing Changes
This is where exercises become especially important.
An exercise isn't just an opportunity to see whether a plan is technically correct. It's an opportunity to see whether the people responsible for executing that plan actually understand what to do.
Staff changes can expose gaps that weren't obvious on paper.
Who takes over when the normal decision-maker isn't available?
Who knows how to activate the EOC?
Who maintains the resource list?
Who understands the relationship with the next level of government?
Who knows what information needs to be pushed out, and when?
These are relatively simple questions until an actual incident occurs.
Regular exercises, training and after-action reviews help identify those gaps before they become operational problems.
Continuity Is More Than a Document
The same issue applies to continuity planning.
A COOP document can identify essential functions, alternate facilities, succession and delegations of authority. But those things need to be understood by the people who may actually have to use them.
A continuity plan that hasn't been reviewed or exercised can quickly become outdated.
Personnel change. Phone numbers change. Facilities change. Technology changes. Vendors change. Responsibilities change.
The document may still say the same thing it said two years ago.
That doesn't necessarily mean the organization is still capable of doing what the document says.
Building Capacity During Normal Times
One of the better opportunities emergency management organizations have is to work on these issues when there isn't an emergency.
That means using normal periods to:
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Exercise plans and procedures
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Cross-train personnel
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Document critical institutional knowledge
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Review succession plans
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Update contact and resource information
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Conduct after-action reviews
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Maintain relationships with partner organizations
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Identify single points of failure
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Test continuity procedures
None of these activities are particularly exciting.
That's part of the problem.
Emergency management tends to receive the most attention when something is already going wrong. But much of the work that determines how well an organization performs during a disaster happens long before the disaster.
The Bottom Line
The recent FEMA ruling will continue to work its way through the courts, and there are still questions about what the ultimate remedies will be.
From an emergency management perspective, however, the broader issue is worth watching regardless of the outcome.
Preparedness is a capability, not simply a collection of plans.
And capability depends on people.
The right staffing level will obviously vary between organizations and missions. There isn't a universal number that guarantees preparedness.
But whatever staffing level an organization chooses, it should be able to explain how that workforce will maintain the knowledge, relationships, training and operational capacity necessary to perform when the plan becomes reality.
That's when preparedness gets tested.
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