Planning for Failure: a framework evaluation of Nova Scotia’s environmental emergency management capacity in the context of tailings dam failure Submitted in partial fulfillment of the undergraduate honours to College of Sustainability, Dalhousie University by Sheena Parris Environment, Society and Sustainability & International Development Studies Supervised by Dr. Peter Tyedmers School for Resource and Environmental Studies Abstract Societies have faced the challenge of understanding and responding to events that threaten life and property for eons, long before any attempts to formalize, study, and institutionalize emergency planning. This research explores the emergency management and the task of evaluating emergency planning documents in the context of environmental emergencies, specifically the hazard posed by tailings dams. This critical document analysis adapts a general emergency management framework evaluation tool designed by Hestra (2010) for this purpose and applies it to key program elements that make up Nova Scotia’s emergency management system. Discussion of the evaluation results indicate the high quality aspects/successes of Nova Scotia’s emergency management system as well as the low quality aspects/gaps, explores the limits of the Hestra framework as an evaluation tool, and the extent to which the system addresses a specific environmental emergency. This research adds a Canadian case example to the relatively new field of environmental emergency management scholarship, and also explores the link between emergency planning and sustainable community development. Key Words: Emergency management, environmental emergencies, tailings dams, hazardous materials spill, sustainability, program evaluation, community development, Nova Scotia 1 Acknowledgements First and foremost I have to extend a huge thank you to my supervisor Peter Tyedmers for his incredible support, compassion, and encouragement. Thank you for allowing me the opportunity to explore this topic under your guidance and for having faith in my abilities. Thank you to the honours teaching team at the College of Sustainability, Susan Tirone, Tetjana Ross, and Andrew Begel, for nurturing our ideas, providing critique, and creating a safe, supportive space to engage with our fellow honours students. To my family, friends – and especially my roommate Caitlyn – thank you for your endless encouragement, support and patience with me through this process, for indulging my stressinduced late-night musical theatre renditions, and for much needed baking parties. Lastly, thank you to the individuals at the Government of Nova Scotia’s Emergency Management Office and Nova Scotia Environment who allowed me access to internal documents to complete my research 2 Table of Contents CHAPTER ONE: INTRODUCTION ............................................................................................. 4 1.1 Problem ................................................................................................................................. 4 1.2 Research Purpose .................................................................................................................. 6 1.3 Limitations and Delimitations............................................................................................... 7 CHAPTER TWO: LITERATURE REVIEW ................................................................................. 7 2.1 Emergency Management ...................................................................................................... 8 2.2 Challenges for Emergency Management Planners ............................................................. 11 2.3 Planning for Hazard-Specific Emergencies: Tailings Dam Failures .................................. 12 2.4 Evaluating Emergency Management Systems .................................................................... 14 CHAPTER THREE: METHODS ................................................................................................. 16 3.1 Searching for an Evaluation Framework ............................................................................ 16 3.2 Data Collection ................................................................................................................... 16 3.3 Analysis............................................................................................................................... 17 CHAPTER FOUR: EVALUATION & RESULTS ...................................................................... 17 4.1 The Hestra Frame ............................................................................................................... 17 4.3 Evaluation Results .............................................................................................................. 19 4.4 Hestra Results Summary ..................................................................................................... 26 CHAPTER FIVE: DISCUSSION ................................................................................................. 28 5.1 Nova Scotia’s Emergency Management Landscape ........................................................... 28 5.2 System Successes and Gaps ................................................................................................ 32 5.3 Environmental Emergency Preparedness ........................................................................... 34 5.4 Limits of the Hestra Framework ......................................................................................... 35 5.5 Opportunities for Future Research ...................................................................................... 37 CHAPTER SIX: CONCLUSION ................................................................................................. 38 REFERENCES ............................................................................................................................. 40 APPENDICES .............................................................................................................................. 44 Appendix 1: Hestra Framework (2010) .................................................................................... 44 Appendix 2: Hestra Criteria descriptions .................................................................................. 45 3 CHAPTER ONE: INTRODUCTION 1.1 Problem Minerals mining industry is a massive contributor to Canada’ economic and social wellbeing (Natural Resoures Canada, 2014), and the products of Canadian minerals mining operations like gold, copper, uranium, and nickel are key components to consumer products that are in increasingly high demand. Most recent estimates place a $44 billion price tag on the value of Canada’s mines, not including as of yet untapped deposits, up from $35.7 billion in 2010 with a massive increase in the productiveness of metals mines from $8.3 billion in 2010 to $23.2 billion in 2013 (Natural Resoures Canada, 2014) (Stothard, 2011). The recent relatively high prices for metals like gold, nickel, and copper reflect increasing scarcity of these elements as well as their essential nature in modern goods like cellphones, computer screens, batteries and vehicles (Stothard, 2011). The modern profitability of minerals mines and new exploratory technology have led both public and private sector decision-makers to re-examine possibilities of expansion in areas of Canada, like Nova Scotia, where such development had previously been deemed impracticable in order to meet growing demand and contribute to economic growth (Beswick, 2012). As a result, policy makers are increasingly concerned with balancing the facilitation of minerals mining development with growing environmental concerns with the goal of fostering a ‘sustainable’ mining sector (Ivany, et al. 2014). Professional mining associations and several levels of government work together to govern this massive industry and to impose standards of practice for the health and safety of the environment, the population and the workers. Minerals mining has a massive impact on the local environment, and the operation of these industrial sites involves substantial effort be put into hazard mitigation, environmental impact assessment and monitoring. Inherent to minerals mining operations are large amounts of chemicals and water that are used to separate the valuable ore from ‘waste rock’. This effluent can be treated to remove or dilute the chemicals and reused until it must be deposited in containment infrastructure such as a tailings dam or containment tower. The effluent these facilities contain are highly toxic containing elements like mercury and arsenic which upon release, either through accidental spill or infrastructure failure, have the potential to cause massive damage to the local environment and to pose significant risk to human health. When 4 these events occur, a well-coordinated, effective emergency management plan is required. Emergency management is a complex public policy undertaking that is often under-funded and given little consideration by officials until it is ‘too late’ (Schneider, 2003). Traditionally, emergency management procedures refer more often specifically to response in cases of natural disasters or acts of terror, and it has been only recently that the idea of a specific ‘environmental emergency management’ strategy has entered into the discussion. Increasingly, emergency management is seen as an integral part of a more comprehensive community decision-making by recognizing that communities must both perceive and manage the risks that surround them. (Schneider, 2003) The recent massive tailings pond failing at the Imperial Metals gold mine on August 4, 2014 brought a spotlight onto discussions of environmental emergency management. The tailings pond at the Mount Polley gold mine was breached after a period of extensive rainfall, resulting in the release of approximately five million cubic meters of effluent containing, among other material, arsenic, sulphur and mercury, into the local watershed (Baker, 2014), an environmental emergency response was required to deal with the implications on both human health and the surrounding nature. In the case of Imperial Metals, the provincial government stepped in as the key agency responsible for orchestrating a response in cooperation with several departments, the local municipality of Likely and NGOs to declare a water ban and pollution abatement order at the Mount Polley site (Baker, 2014). Currently, the extent of the environmental damage and fate of Imperial Metals’ operations at that mine are unknown. Today, public and private discourse around the continued pursuit of minerals mining is occurring in the context of sustainable development. Economic assessments like the One Nova Scotia report (Ivany, et. al, 2014), legislative and regulatory objectives put forth by the Canadian Department of Natural Resources, and industry associations like the Mining Association of Canada have all explicitly identified ‘responsible’ mining as a goal. Pursuing responsible mining operations necessitates a life-cycle approach that addresses all aspects including from project siting to remediation and recognizes the risks associated with each ‘stage’ of a mine’s life, including contingency planning for if and when something goes wrong. Traditionally, emergency management has been understood as mainly reflexive function of public policy which concerns few outside the specific first responders (Schneider, 2003). However, increasingly the logic of long-term, integrated emergency management is being 5 recognized by practitioners who see critical opportunity in the incorporation of emergency management into wider community development decision-making (Beatley, 1995). Strategic or New Emergency Management seeks to move away from the ‘old’ reaction/recovery model in favor of proactive focus on hazard mitigation integrated within a broader sustainable community development context for both natural and manmade disasters (Schneider, 2003). This broader, sustainability-minded understanding of emergency management one lens through which we can begin to understand and analyze how managers can improve on their response to terrestrial environmental emergencies. 1.2 Research Purpose The purpose of this study is to explore Nova Scotia’s provincial emergency management system and to evaluate this system in the context of environmental emergencies, specifically a potential hazardous materials release caused by a tailings dam failure. The primary research question is: to what extent is Nova Scotia prepared for an environmental emergency? This inquiry is further guided by three key sub-questions: 1. What are the elements or best practices that make up a ‘good’ emergency management system? 2. Who is in charge in the case of an environmental emergency in Nova Scotia? 3. How can we evaluate both the emergency management system and the extent to which it considers environmental emergencies? The larger context of these questions are attempts to discern how we, both in Canada broadly and in Nova Scotia, can establish decision-making process and tools for a more environmentally and socially responsible mining industry. Like most questions of sustainability, this is a ‘wicked’ problem (Rittel & Webber, 1973) characterized by multiple crucial facets, including everything from policy to individual practice, that involves the interests of many stakeholders with no distinct ‘right’ or ‘wrong’ answer. The assertion of this study is that environmental emergency response planning is one of the many important aspects Nova Scotian policy makers must keep in mind as they work towards the goal of a more responsible mineral extraction industry in this province. In addition, this research is potentially significant as it will provide insight into the aspects of environmental emergency management planning in which Nova Scotia excels, identify 6 potential gaps or areas to be improved, and promote the value of pre-emptive emergency management planning. Hopefully, this work will also serve to facilitate discussion around the current emergency management capacity in Nova Scotia and expand on emerging literature on environmental emergencies. It will also contribute a Canadian case study to a field dominated by literature from Europe, the US and China. 1.3 Limitations and Delimitations This study was limited by access to provincial emergency planning documents. The scope of this study was also limited as to reflect the time and resources available. The study did not seek to deeply analyze or critique the legislation at various levels of Canadian government which regulate extractive industry, emergency management or pollution incidents, nor will the study examine the merits of certain containment technologies. Rather, the focus was on the actual plans currently in place that are accessible to public responders in the case of a hazardous release due to a tailings dam failure. Moreover, though industry stakeholders are increasingly concerned with emergency preparedness and response planning (Sanford, 2012), this study will not seek to incorporate or analyze plans developed by private groups. This is to reflect the implications of the definition of ‘emergency’ as related to planning in each province where when there is a threat to human wellbeing and environmental integrity - provinces have the authority and responsibility to coordinate effective response. CHAPTER TWO: LITERATURE REVIEW In order to address the question of Nova Scotia’s environmental emergency management capacity, it is first important to explore the evolution of emergency management as a field, the barriers emergency managers face, they specific challenges of tailings dams, and the broader theory around emergency management program evaluation. Insights from the authors below include a general acknowledgement of the lack of robust, consensus-driven scholarship around emergency management, particularly in the case of environmental emergencies and the task of evaluation. However, most also point to the important of undertaking systematic academic exercises around emergency management and to the idea that while having a plan is much better than having a plan, there is no guarantee that in practice things will always go according to said plan. So, it is important to keep in mind that many of the processes and systems described below 7 are by their nature speculative and that reiterations of these systems tend to happen in response to new or worsening emergency situations. 2.1 Emergency Management Societies have faced the challenge of understanding and responding to events that threaten life and property for eons, but it has been only relatively recently that ‘emergency management’ has become an institutionalized function of local governments and a topic of academic scholarship in its own right. Emergency managers engaged in the task of preparing for emergencies must identify risks to people and property, assess the vulnerability of communities and establish clear response protocols with the aim of minimizing loss. In the past, managing emergency events has been a task reserved for first-responders, and it occurred in a relatively informal, ad-hoc way (Schnieder, 2003). The US Federal Emergency Planning and Community Right to Know Act of 1986 is cited as the first attempt to mandate and planning functions across all levels of government ; it also gave citizens the explicitly right to demand information and consultation around risks in their local areas (Wolf, 1996). Briefly, it is important to speak to the fact that there are many ways of defining what counts as an ‘emergency’. In Nova Scotia, an emergency is defined as “a present or imminent event in respect of which the Minister [of Justice] or a municipality, as the case may be, believes prompt co-ordination of action or regulation of persons or property must be undertaken to protect property or the health, safety, or welfare of the people in the Province” (Government of Nova Scotia, 2011). Emergency management scholarship differentiates between hazards, emergencies, and disasters. The term ‘disaster’ is applied only to events where the magnitude of loss exceeds response the capacity of the community, while ‘emergencies’ are more minor, routine events that cause consequences, but are more well understood and can be dealt with effectively by standardized response protocols administered by local/regional services (Lindell, Prater & Perry, 2006). ‘Hazards’ are the natural processes and artificial developments that have the capacity to do harm (Lindell, Prater & Perry, 2006). However, disaster theorists have noted that it is important to recognize that emergency events are not caused by hazards; rather, they are caused by the failure of human societies to effectively adapt to and safely interact with their environment (Carr, 1932). 8 For emergency management academics and professionals, the basic assumption is that emergency events will occur and that preparing response procedures will minimize the scale of loss damage (Jat, 2008). Most often, these plans take all-hazards approach, meaning that a single response plan is created to deal with both natural hazards, such as earthquakes and severe storms, and human-social hazards, such as terrorism and technological activities are treated synonymously (Beately, 1995). In the past, these plans have dealt almost exclusively with emergency response and the technical capacity of a government to carry it out. Reactive approaches to emergency management planning are disaster-driven, limited their capacity to minimize loss, and they fail to garner political or public interest (Perry & Mushktel, 1984). This ‘old emergency management’ paradigm, as Schneider explores, fails to recognize the long-term logic of integrating emergency preparedness, vulnerability assessments, land-use planning and other mitigation measures, response protocols, and recovery efforts into broader community planning (2003). The ‘new emergency management’ paradigm (Schneider, 2003) or ‘Strategic Emergency Management’ (STEM) (Paton, 2000), shifts focus from reactive emergency management systems to proactive planning and community development integration. Drawing on sustainable development concepts, emergency managers are increasingly linking emergency planning to broader environmental, social and economic development concerns (Waugh, 2005; Paton, 2000). In this new paradigm, emergency preparedness requires emergency managers to be trained as public policy administrators, to integrate all four functions of emergency management (preparedness, mitigation, response, and recovery), and, in accordance with sustainable development principles, meaningfully engage stakeholders in these community planning activities (Beatley, 1995; Waugh, 2005). Emergency managers must understand vulnerability, or the extent to which communities and specific groups within those communities are likely to be damaged or impacted by a hazard, and recognize that vulnerability is socially constructed (Jat, 2008). It is assumed that this fundamental integration of emergency preparedness planning and long-term community development will reduce the impacts of emergency events more effectively than the ‘old’ paradigm, because it is proactive and requires emergency managers to engage with and educate the wider public (Schneider, 2003). Public policy officials may also garner more attention and political support for emergency preparedness under this paradigm (Waugh, 2005). 9 While the ‘new’ paradigm also relies on all-hazards approaches to planning, it does so only in so far as to reduce the reliance on react-response emergency management models; hazard-specific planning must also occur. It is only logical to recognize that the magnitude of loss, response protocols, and predictability of long-term impacts will differ in practice between, for example, a tsunami, a terror attack and a tailings dam collapse. For the purposes of this study, it is important to briefly expand on how environmental emergencies and environmental emergency planning fit into this discussion. The characteristics of the specific hazard at hand – tailings dams at mining sites – are explored later. Environmental emergencies or technical emergencies as some authors refer to them, are defined in Canada as (1) “an uncontrolled, unplanned, or accidental release, or release in contravention of regulations or interim orders made under this Part, of a substance into the environment; or, (2) the reasonable likelihood of such a release into the environment” (Government of Canada, 2002). More broadly, they refer to events that are characterized by their negative, short or long term impacts on land, air quality, water quality, natural systems and organic and inorganic matter as well as their direct impacts on human systems or property (UNEP, 2002). Environmental emergencies are often cumulative they can be caused by or contribute to other emergency events (Lindell, Prater & Perry, 2006). For example, the BP Deepwater Horizon Disaster in 2010 that killed 11 people, threatened over 400 animal species, destroyed the livelihoods of thousands, and began with a more general emergency – a rig fire and explosion (Westall, 2015). The eventual release of approximately 650 million litres of oil into the Gulf of Mexico is lauded as the greatest environmental disaster in US history. There were dozens of hazardous-materials releases that were directly tied to both the actual meteorological impacts Hurricane Katrina (high winds, flooding) and the social upheaval following the response (Cruz & Krausmann, 2009). Planning for and responding to environmental emergencies forces emergency managers to seek environmental, chemical and biophysical science enterprise, create hazardous materials management training for managers, perform water and soil quality monitoring, recognize the ways our systems are vulnerable to pollution, and implement mitigation strategies to protect both people and ecosystems (Belling, 2001). For many governments, particularly for governments in the Global South, these tasks are not feasible or high-priority, but there is increasing international pressure from supranational bodies like the IFC, UN, WB and IMF to ensure proponents have contingency plans in plan before projects are funded/approved (Sanford, 2012). 10 2.2 Challenges for Emergency Management Planners Today, emergency events are becoming increasingly frequent and damaging, and emergency managers must grapple with psychological, institutional, and funding shortcomings in their efforts to prepare for more disasters. As Quarantelli notes, characteristics of our modern society such as urbanization have resulted in an ever-increasing number of people gathering in dense, urban areas, meaning that when disasters strike urban areas, the loss of life, property and social stability is often much greater (1996). There is compelling evidence suggesting that industrialization, anthropogenic climate change, and the resulting biophysical process disruptions is resulting in growing uncertainty around the integrity of both old new infrastructures and putting more people at risk (Lemmen, Wattern, & Lacriox, 2008; Quarentelli, 1996). Emergency managers must also consider that climate change can also negatively impact resilience of communities and increase the vulnerability of social systems by destabilizing traditional economic systems or access to ecosystem services that would otherwise support response and remediation efforts in the event of an emergency (Cutter, et al., 2008). Emergency managers understand that human psychology and institutional challenges play a huge part in our capacity to understand risks, plan for emergencies, and responds effectively in crisis situations. We even struggle to plan effectively for emergency situations that we have experienced before or have a good grasp on in terms of likelihood and magnitude of damage – or ‘predictable surprises’ (Bazerman & Watkins, 2004) One contributing factor to this is that planning institutions tend to emphasize probabilistic thinking over possibilistic thinking (Clarke, 2007). Probabilistic thinking relies on the measurable probabilities of a hazard occurring, how much damage it might inflict, and on whom; it is based in reasoned, empirical data and is viewed as the ‘normal’ way to approach decision making. However as Clarke explores, an exclusive focus on probabilism can cause planners to forget or discount worse case disaster scenarios which can lead decision-makers to justify dangerous developments (2007). While there is no doubt that understanding probability and risks is vital to emergency management planning, it’s important to note the influence of cognitive biases and institutional information systems failures that skew the extent to which we can completely understand and act on probabilities. Bazerman and Watkins explore the implications of social psychology literature to enumerate several reasons why we, as individuals and as collectives, struggle to mitigate and prepare for emergencies. These reasons include (1) the fact that we tend to hold overly positive 11 illusions about ourselves, the probable severity of the consequences of our (in)action, and our ability to control uncontrollable events, (2) we are unable to make unbiased decisions ,(3) we more prone to errors of omission (doing nothing) than errors of commotion (causing harm; taking risk) which maintains status quo, (4) we focus on short-term harm and discount the future harms, and (5) we struggle to invest in problems we have not experienced them personally. In addition, institutions who undertake emergency management functions can struggle to effectively plan for and respond to emergencies due to failures of information scanning, integration, lack of incentives, and organizational learning disabilities resulting from personnel loss and bureaucracy. (2004) Moreover, the relatively low prioritization in most communities for comprehensive emergency management planning efforts means that the work is chronically under-funded and under-resourced (Schneider, 2003) Recognizing problems as such before they occur, particularly at an organization level, requires a well-defined vision, disciplined learning processes, network building and scenario planning (Bazerman & Watkins, 2004). However, local governments rarely have the motivation or ability to devote to the resources to such intensive emergency preparedness efforts (Hestra, 2010; Wolensky & Wolensky, 1990). Due to the institutional and human psychology factors discussed above, emergency preparedness tends to only make it onto the agendas of policy makers in the event of a high-loss disaster (Schneider, 2003; Beatley, 1995). 2.3 Planning for Hazard-Specific Emergencies: Tailings Dam Failures As all hazards cannot effectively be addressed through a single lens, neither may environmental emergencies be treated as completely synonymous. The specific environmental emergency this study examines is the event of a large-scale terrestrial hazardous materials release resulting from the failure of a tailings dam. As such, it is necessary to spend some time exploring the specific characteristics of tailings dams, the reasons they fail, and the implications of such a release. It is important to note that nearly all authors in their discussions of these events point to the lack of baseline environmental data, public information about the contents of tailings ponds, and true data on the rates of failures as serious issues for planning and response. In short, tailings dams are containment facilities used by industry to contain liquid waste near the site of work. They are some of the largest man-made industrial structures, and account 12 for the highest volume of waste in extractive industries (Davies, Martin & Lighthall, 2002). In a mining context, these tailings dams contain what is called process water, typically a blend of unwanted minerals, leftover dust and ore, and process chemicals including hydrometallurgical reagents like sulfuric acid, activators and depressants like lead nitrate, hydroxides, flotation reagents including alcohols, tars, and many more (Lottermoser, 2010). Tailings dams take one of four main structural forms depending on the local topography, hydro-geology, climate, design specifications, cost and available construction materials : (1) Specially Dug Pits, (2) RingDykes,(3) In-Pit Systems, or (4) Valley Designs - with the latter being the most common (EPA, 1994). Valley Designs rely on natural topographic depressions near the mining site that are dammed with embankments, made usually with local materials, creating a containment area for the process water (EPA, 1994). These structures are well-understood, but under-regulated in terms of design criteria as each is engineered for specific situations, and while Valley Designs save cost upfront by using local materials as fill, the maintenance of these dams is very costly. (Rico, et al., 2007). Tailings dams should be constructed to hold the process water indefinitely, but non-active tailings are rarely sufficiently monitored or improved as environmental conditions change (Lottermoser, 2010). Public interest in the risks associated with tailings dams have been growing worldwide in the wake of massive disasters like the Aznalcollar sulphide tailings spill in 1998, the Baia Mare, Baia Borsca and Aitik Mine mining chemical releases in 2000, and the recent Mount Polley disaster in August 2014. Despite massive investment in research, technology development, regulatory programs, and transnational industry organizations addressing concerns around tailings dams over the last 30 years, there has constant rate of failure of about 1 per year (Davies, Martin & Lighthall, 2002). In a massive study conducted by Rico, et al. on tailings dam disasters, the authors analyzed 147 cases from around the world to find that 90% of failures occur on active mine sites, 39% of the failures were attributed to a combination of meteorological events like heavy rain/snow and the resulting overflow/structural damage, 10% of worldwide cases, and 12% of European cases were attributed to poor or deficient application of management or safety regulations (2007). Other factors that contribute to containment failures include engineering errors, misevaluations of environmental stresses like rainfall or an earthquake, operational problems such as failure of electricity supply or fire, and delayed or inadequate execution of maintenance work (Modoi, et al., 2000) Engineering and design decisions around these 13 controversial structures suffer from an all-or-nothing consultative approach where firms tend to either dismiss the insights of third-party consultants/case studies, resulting in a design decisions that is based on ideals rather than what will work on the ground , or firms will reject outside expertise, resulting in systems which may not be completely thought out (Davies, Martin & Lighthall, 2002). These factors must also be considered within the context of relatively low institutional capacity to enforce monitoring and maintenance regulations (Modio, et al., 2000). The impacts of tailings dam failures are not well-understood outside of the face-value losses such as physical property damage caused by the release, making it very difficult to develop specific response guidelines. As discussed previously, lack of detailed information about the contents and concentration of the process chemicals, insufficient baseline data, and slow response times to monitor the aftermath are challenges to drawing conclusions about the longterm impacts of these disasters (Modoi, et al., 2000; Lottermoser, 2010; Rico, et al., 2007). Short term impacts in regards to cyanide levels in released tailings water were studied by Mudder & Botz (2004) who discuss aquatic systems, migratory birds, and terrestrial animals as the primary groups of concern. In general, fish kills, human deaths, water pollution, and sediment contamination are common ways to measure short-term impacts (Lottermoser, 2010). In the effective management of these risks, Modoi, et al. (2000) suggests that future impact studies must understand not only the potential of the pollutants contained in the process water but also the specific ecological context in which they are released in order to develop usable best management and effective monitoring practices. 2.4 Evaluating Emergency Management Systems One of the greatest challenges facing public mangers today, and the primary task of this research, is that of program evaluation. In the case of emergency management, they system and its components are often not meaningfully examined until they fail in practice (Bazerman & Watkins, 2004). Measuring performance in public works, particularly in the case of emergency management programs, can be extremely difficult due to complexity of problems, intangibility of outcomes, and uncertainty (Alexander, 2005). The lack of resources and salience with public officials that plagues emergency managers extends to the task of evaluation, and absence of local emergency experiences makes it difficult to identify gaps in a system (Hestra, 2010). 14 Evaluations of emergency plans are important for many reasons. Inefficient or incomplete management can create/deepen chronic emergency needs by failing to link or develop resources and procedures. (Alexander, 2005) Static emergency management systems that are not defined or practiced can lead to avoidable damage or casualties, and evaluations can help identify gaps in a given system (Alexander, 2005). While environmental and property damage is most likely to occur as a result of a tailings dam failure, it is important to note that even events that do not lead to casualties, if poorly managed, can contribute to social disruption, political unrest, and economic cost. (Quarantelli, 1996) Additionally, evaluations can act to strengthen accountability and to promote the value of these systems in order to demonstrate need for further public investment (Hestra, 2010). As Rusch asserts, ultimately public managers look to defined measurables to in order to make decisions around resource allocation and priorities; without proactive evaluations to give them measurables, emergency management will not make it onto the agenda until something goes wrong (1993). There are many ways to evaluate emergency management programs, and the academic literature is full of attempts to operationalize and create a methodology around this task. Some attempt to develop standards of functionality, efficiency and accountability (Alexander, 2005) while others, problematically, look solely to the past for guidance on ‘what went wrong’ (Quarentelli, 1995). Guidelines or ‘guiding principles’ have been developed by both academics and professionals as an attempt to understand the necessary aspects of ‘good’ emergency management components, often emerging in practice as checklists (Hestra, 2010). Burnett conducted a systematic literature reviews with the intent of developing management strategies and crisis identification matrices to most effectively approach the planning and response processes (1998). Despite these and many other attempts there is relatively little consensus among research as to the ‘best’ or ‘most effective’ evaluation tool, and scholars in the field note the abstract conceptualizations of emergencies, specific-hazard emergency response protocols, and jurisdictional differences as barriers to rigorous, widely applicable evaluations tools (Lindell, Prater & Perry, 2006). It is critical to note that while emergency management system evaluations are critical to continual improvement, improving salience amongst public officials, and strengthening government accountability; their results cannot be regarded as absolutely predictive of success or effectiveness (Alexander, 2005). 15 CHAPTER THREE: METHODS In order to attempt a risk-specific evaluation of Nova Scotia’s emergency management system, it was necessary to conduct systematic data collection using internet databases to first identify a best fit evaluation framework, then to identify information, documents and policy within the system for analysis. 3.1 Searching for an Evaluation Framework As the purpose of this study is ultimately to address the question of Nova Scotia’s preparedness for an environmental disaster, the first step was to identify a best-fit evaluation tool. The search for this tool was guided by insights from the general literature on emergency management, the task of program evaluation, and the specific limits of this study. Therefore, it was essential for the evaluation tool to (1) be grounded in a STEM approach that recognizes the importance of all four stages of emergency management planning and the need for multistakeholer engagement, (2) provide specific, measurable results, (3) adaptable to a risk-specific context, and (4) balance depth of analysis with the time and resources available for this study. Options for evaluation tools were found through internet database searches (Google, Novanet, WorldCat) focusing on combinations of key terms such as ‘emergency’, ‘emergency management’, ‘preparedness’, ‘emergency planning’, ‘emergency response’, ‘evaluation’, ‘framework’, ‘best practices’, ‘tool’, and ‘decision making’. ‘Disaster’, ‘hazard’, and ‘emergency’ were treated as synonymous terms at this stage. 3.2 Data Collection Once a best-fit evaluation tool was identified, it was necessary to assemble the documents, web-pages, and relevant policies at the provincial level that would act as the emergency system data. These data were systematically gathered using internet searches to mine the official Government of Nova Scotia website and Google for publically available documents, manuals, and policies addressing the task of emergency management. In addition, requests were made to individuals from the Emergency Management Office (EMONS), Nova Scotia Environment (NSE), and the Nova Scotia Department of Natural Resources (DNR) for access to updated/unpublished emergency management planning documents such as manuals, training materials, or program guides. The EMO pointed to an updated copy of the Nova Scotia 16 Emergency Response Plan (2012), and NSE provided copies of the Environmental Monitoring and Compliance Division Emergency Response Manual (2009) and the Nova Scotia Environmental Emergency Response Plan (2008). DNR did not provide any documents, despite initial interest and repeated contact attempts. The publically available data sourced for analysis were: Information found on Government of Nova Scotia website including the Emergency Management Office, Department of Community Services, Department of Municipal Affairs, DNR, and the Department of Transportation sections. Susceptibility & Risk Hazard Assessment (EMO, 2010) Emergency Management Act (2005) Business Continuity Management Program (EMO, 2012) 3.3 Analysis The data were sorted and analyzed in a matrix constructed from the best fit evaluation tool – the Adapted Hestra Frame. A careful reading of each of the emergency system data elements was conducted, and information was synthesized, summarized, and sorted within the. Each criterion then received either a presence-absence or low- medium- high quality designation as per the Hestra evaluation structure (see Appendix 1). Each designation was justified and translated into a weighted score .The results were then subjected to thematic analysis where gaps and successes of the system were identified and explored in their relationship to the system’s characteristics and overall quality. CHAPTER FOUR: EVALUATION & RESULTS 4.1 The Hestra Frame The ‘best fit’ tool chosen for this study was a framework evaluation created by David Hestra to aid local governments in evaluating their general (all-hazards) emergency management system. The Hestra Frame is based on an extensive literature review of both emergency management literature and previous evaluation strategies including check-lists, best practices manuals, and policy guidelines. Providing an extensive list of 30 key criteria (Fig. 1) supported 17 by the literature and divided into the four key emergency management planning stage, the Hestra Preparedness Emergency manager Program committees Hazard identification and risk assessment Response plan Annual plan review By-Law Training Exercises Mutual aid agreements Critical Infrastructure protection Special needs planning Business engagement Mitigation Mitigation plan Warning system Public education Dangerous goods routing by-law Risk-based land-use planning Response Emergency operations center Incident management system Evacuation plan Emergency shelter arrangements Volunteer management Community emergency response teams Search and rescue Emergency public information Recovery plan Continuity planning Damage assessment Debris management Rehabilitation Frame evaluates the ‘quality’ of an emergency management system which he argues is a causal factor in the effectiveness of emergency response. Quality is defined as “the extent to which a local government has adopted policies to prepare for emergencies, mitigate their impacts, ensure an effective emergency response, and facilitate community recovery”. Hestra describes each criterion (Appendix 2) and creates a framework around what it takes for a system element to achieve a low, medium, or high-quality score (see Appendix 1). While each of the 30 criteria is considered essential aspects to a high-quality system, they are not all equal in the eyes of the literature. As a result, Hestra adds an additional layer of complexity by creating a weighted scoring system to reflect the importance of one criterion over another. Emergency management system data such as documents, policies, and webpages can then be analyzed one Recovery criterion at a time in order to determine the quality of the system as a whole (2010). Fig 1: List of Hestra Criteria The Hestra Frame was the best fit tool chosen because it is supported by academic literature, it provided a well-articulated evaluation template that was feasible to apply to the provincial system in Nova Scotia in the time available, and it represented a STEM approach by incorporating key considerations from preparedness, mitigation, response and recovery planning. While it does not explicitly address the desire for a specific environmental emergency management system evaluation tool – there was no tool found that did this specifically – Hestra notes in his discussion of the framework that modifications should be made in to better address the needs, vulnerabilities, and characteristics of each jurisdiction and application. As a result, in 18 the analysis of Nova Scotia’s emergency management system, an additional evaluative column was added to track instances of specific consideration of environmental emergency and/or mining hazards and/or large, land-based hazardous materials releases that would be characteristic of a tailings dam failure. 4.3 Evaluation Results Reporting Table Legend Hestra frame point (given) see Appendix x for full criteria descriptions, and Appendix x for the original framework including the weighting scheme and for definitions of low, medium and high quality results. Hestra frame point (not given). Weighing limit per criterion. As per Hestra’s frame, criterion that are given a higher weighting have more possible points which reflects their importance to a high-quality EMP as reflected in the literature. (2010) Criteria with one possible point are weighted 1 and are characterized as present/absent criteria. Explicit environmental emergency and/or hazardous materials spill and/or mining-related consideration is addressed in the provincial planning document. Environmental consideration not present. PREPAREDNESS 28 of 32 possible Hestra points are fulfilled by the Nova Scotia Emergency Management System documents analyse 6 of 12 Hestra criteria address specific environmental emergency considerations Emergency Manager Within the Nova Scotia Emergency Management Office, there are full-time individuals responsible for EM and preparedness functions (EMO, 2015). In addition, within each provincial department, there is a designated Departmental Emergency Response Coordinator (DEPO) who plans for the specific needs and risks of their respective departmental portfolios. In the case of an environmental emergency, including the event of a hazardous materials release as result of a tailings dam failure, Nova Scotia Environment’s (NSE) DEPO would have the resources and training to mobilize resources and coordinate with other levels of government (NSEERP, 2008, p. 18). Program Committees 19 There exists a multi-stakeholder Executive Emergency Management Committee (EEMC). This committee is chaired by the Minster of Public Affairs, and the committee includes several senior representatives including the Deputy Minister of the Treasury, representatives from the EMO, Department of Justice, Office of the Premier and other experts. There is no explicit consideration of environmental emergencies in the description of this committee, though it is likely that the EEMC holds such events within its portfolio. (NSERP, 2012, p.23) Hazard ID & Risk Assessment Nova Scotia’s EMO developed a ‘Susceptibility Analysis’ which outlines 74 vulnerable groups in Nova Scotia and to which kinds of emergencies each group is most vulnerable (2010). No risk assessment was found identifying industrial or geological risk factors as hazards for response planning; however, the NSEERP (2008) does identify several environmental hazards, including land-based chemical spills, and the EMCDM (2009) provides a basic overview of the response characteristics for each event. Response Plan Nova Scotia has a well-developed, all-hazards Response Plan the clearly outlines response protocols for crisis decision making. The document is the key EM resource for the province. (2012) NSE also has a comprehensive environmental emergency response plan. (NSEERP, 2008) Plan Review An annual review of Nova Scotia’s Emergency Response Plan is legislated to occur on an annual basis through the Emergency Management Act (EMA). This review is meant to be substantive, including consultation with other departments and experts in order to ensure continuous improvement and integration. (2012) Hazard specific plans, including those dealing with the release of hazardous material, compromised potable water systems, and flooding, receive a review every 2 years min. (NSERP, 2012, p. 33) By-Law 20 According to the Emergency Management Act (EMA), municipalities are required to implement an emergency management by-law that includes provisions for a senior advisory committee as well as the creation of an emergency management plan (EMP) (NSERP, 2012, p.59) The EMA does not give any specific requirement for environmental emergency planning. Training Awareness training for EM policies and plans is required for all NS employees (auxiliary staff). Emergency Management Planning Officers (EMPOs) are trained in managing diverse situations and regional EMPOs laisse with vulnerable stakeholders including first Nations groups in attempt to deliver resources for response in the case of an emergency (EMO, 2015). More advanced training for senior officers is administered upon hire and renewal is not mandatory (NSERP, 2012, p.28). EMPOs hold experience in multi-hazard situations such as hazardous materials spills and mining disasters, and extensive training on such events occurs on a recommended 5-year rotation. (NSEERP, 2008, p.55) Exercises According to the Emergency Management Training portal on the EMO website, tabletop exercises occur for EMPOs several times a year; but there is no indication of a province-wide simulated exercise schedule (2015). NSE holds table-top exercises for environmental emergencies every 1-2 years, and simulated exercises occur every 2-4 years. (NSEERP, 2008, p.58) Mutual Aid Nova Scotia has mutual aid agreements between provinces, the federal government and the US through the International Emergency Management Assistance Compact signed in 1998. The mechanisms/situations which activate these agreements are explored in the NSERP (2012, p.67). These documents reflect an all-hazards approach. Critical Infrastructure Protection 21 EMO has developed Critical Infrastructure Response Plans (CIERPs) and they collaborate with key infrastructure systems including NS Power, sewage and potable water providers, and telecommunications to develop these plans (NSERP, 2012, p.67). No CEIRP was acquired during the course of this resource, so the extent to which they may address specific environmental, hazardous-materials, or mining concerns was not determined. Special Needs Planning NSERP included provisions for the protection, care and attention to persons with disabilities (2012, p.31). Business Engagement NSERP notes industry and private sector collaboration in the development and assessment stages of emergency management planning, including involving these stakeholders in risk-specific response strategies, CEIRPs, and business continuity (2012,p.70). MITIGATION 3 of 8 possible Hestra points are fulfilled by the Nova Scotia Emergency Management System documents analysed 0 of 5 Hestra criteria address specific environmental emergency considerations Mitigation Plan No articulated mitigation planning was found to address the need to reduce vulnerability of people to hazards or to identify mitigation goals and strategies. Warning System Municipalities are in primarily responsible for local warning systems, and provincial emergency call outs occur through radio, television, official webpages and government social media. (NSERP, 2012, p. 9) Public Education 22 Public information is available online through the EMO website. Dangerous Goods Routing By-Law The Dangerous Goods Transportation Act (1989) and associated hazardous materials, transportation by-laws, and environmental regulations, act together to protect the public and critical infrastructure from an accidental release as a result of shipment accidents. (Department of Transportation, 2015) Risk-Based Land-Use Planning ? Under the Municipal Government Act (1998), municipalities are empowered to enact land-use by-laws in order to support planning strategies. These land-use by-laws require a public consultation process and should consider “existing land use and location, size, soil type, and conditions of local watersheds”. (GMA, 1998) In addition, the Department of Natural Resources is in charge of creating a comprehensive understanding of Nova Scotia’s geohazards such as flooding, coastal erosion, and landslides. (DNR, 2015) This criterion receives half a point because, though risk-based land-use planning exists conceptually, it is never explicitly tied to the EM planning processes. RESPONSE 14 of 17 possible Hestra points are fulfilled by the Nova Scotia Emergency Management System documents analysed 4 of 8 Hestra criteria address specific environmental emergency considerations Emergency Operations Center Incident Command Centers are established on the scale/characteristics of the emergency and the communication/response capacity of the given jurisdiction. (NEERP, 2008, p. 25) There are established protocols and procedures that differentiate between command structures based on certain kinds of emergencies, including environmental emergencies. (NEERP, 2008, p. 25) Municipalities are responsible for designating a physical Emergency Operations Center that is suitable and staffed for 25hr operations, data analysis, and communication. (NSERP, 2012, p. 64-65) 23 Incident Management System Nova Scotia trains all staff in an Incident Command System (ICS), and they system is designed to be adaptable, interdisciplinary and ensure support for all levels of the command chain. In the case of environmental emergencies, Levels 1-3, NSE is the defined lead agency for response management (NSERP, 2012, p. 42). Evacuation Plan Municipalities are responsible for the development of clear evacuations plans in the event of an emergency; however, the JEOC does also have jurisdiction as a lead agency in a major event which required mass evacuations (NSERP, 2010, p. 59). No examples detailed of NSE or EMO evacuation plans were found. Emergency shelter arrangements As per agreements made with Nova Scotia Community Services, the Canadian Red Cross assumes responsibility for the planning, training and response functions associated with emergency social services (ESS) including shelter arrangement (2015). It is noted that specialised ESS planning occurs in relation to technological and environmental accidents with chemical spills listed as an example (NSCS, 2015). Volunteer management Donations and volunteer management are not tasks for which the provincial EMO is responsible. (NSERP, 2012, p. 73) Community emergency response teams CERTs do not exist as subsidiaries of the provincial emergency management structure. Search and rescue There exists a developed plan and staffing for search and rescue in the case of emergencies. (EMO, 2015) No indication was found pointing to specific training for consideration for environmental emergencies, though it is assumed that search and rescue training involves 24 hazardous materials awareness. Emergency public information Nova Scotia uses web, television, and radio-based emergency alert platforms to communicate to the public. (NSERP, 2012, p.9) Each department, including NSE, in the case of an emergency has an identified Public Information Officer (NSERP, 2012, p.25). In the NSE response command chain, a media relations officer and communications liaison work closely with the JEOC. (NSEERP, 2008, p. 15) RECOVERY 4 of 8 possible Hestra points are fulfilled by the Nova Scotia Emergency Management System documents analysed 0 of 5 Hestra criteria address specific environmental emergency considerations Recovery Plan No articulated emergency recovery plan was found. Continuity planning All provincial departments are required to have plans to maintain essential services in the case of emergency, and there are resources developed to help private businesses plan for business continuity. (EMO, 2012) Damage assessment Post-emergency, a federally-funded, provincially coordinated Disaster Financial Assistance Arrangement unit is responsible for damage assessment and fund distribution. (NSERP, 2012, p. 72) Debris Management No articulated debris management plan was fund. Rehabilitation It is noted in the NSERP that the provision of psychosocial services for both first responders and 25 victims is critical, though no articulated plan or clear responsibility designation for this function was found. (NSERP, 2012, p. 70) 4.4 Hestra Results Summary Five key documents, the Nova Scotia Emergency Response Plan (2012), Nova Scotia Environmental Emergency Response Plan (2008), Emergency Susceptibility Analysis (2010), Business Continuity Management Program (2012), and Emergency Management Act (2005), were analyzed through this framework along with information available through official department webpages.Based on these documents, the general emergency management system in Nova Scotia at the provincial level is of medium-high quality with a Hestra score of 75.4% (49/65 points). As shown in Figure 2, the highest quality stage in Nova Scotia’s emergency management planning system is Preparedness with 87.5% (28/32) fulfilled Hestra points with Response following at 82.4% (14/17), Recovery at 50% (4/8), and lastly Mitigation at 37.5% (3/8). Summary Result of Hestra Frame Analysis of Nova Scotia's Emergency Management System by Stage 35 4 30 28 Hestra Points 25 20 Hestra Points Unfulfilled 3 15 Hestra Points Fulfilled 14 10 5 5 4 4 3 0 Preparedness Mitigation Response Recovery Figure 2: Summary of Hestra frame results per stage of emergency management planning including the amount of points possible for each stage, the points fulfilled, and the points unfulfilled. 26 Explicit planning consideration of environmental emergencies occurred in 1/3 of Hestra’s framework criteria with the overwhelming majority of relevant data coming from the NSEERP. As shown in Figure 3, of the 30 criteria, 6 in the Preparedness stage and 4 in the Response stage explicitly dealt with environmental emergencies and/or situations linked to the release of hazardous materials. There were no environmental considerations found relating the Hestra criteria in the Mitigation or Recovery stages. Summary Results of Environmental Consideration in Nova Scotia's Emergency Management System Response criteria with environmental consideration present 4 6 20 Preparedness criteria with environmental consideration present Hestra criteria (all stages) without environmental consideration Figure 3: Summary of NS EMS Hestra frame analysis focusing on the presence or absence of environmental consideration 27 CHAPTER FIVE: DISCUSSION 5.1 Nova Scotia’s Emergency Management Landscape In Nova Scotia, the emergency management system emerges from the authority, responsibilities and powers assigned to provincial public officials by the Emergency Management Act of 1990 (amended 2005). The purpose of the Act is to ‘provide for a prompt and coordinated response to a state of emergency’ and is administered, currently, by the Minister of Justice and the Executive Emergency Management Committee (EECC) (Government of Nova Scotia, 2011) though the Emergency Management Office (EMO). The EECC is composed of the Minister of Justice, Deputy Minister of the Treasury Board, Deputy Minister of the Office of the Premier, Deputy Minister of Justice, and other experts appointed by the Minister. This interdisciplinary team is tasked with providing “oversight and direction to the Minister regarding emergency preparedness, response, mitigation, and recovery” (Emergency Management Act, 2005). A complete, extensive breakdown of the divisions and duties of public officers within the Emergency Management Office and all other provincial departments are available in the Nova Scotia Emergency Response Plan, but for our purposes this discussion is limited to (1) the sources of the documents analyzed as a result of the evaluation and (2) the duties and reporting relationships activated by an particular environmental emergency – a tailings dam failure. There are many other actors involved in Nova Scotia’s emergency management system (See Fig 1). Canada’s federal Emergency Management Act requires provinces to legislate their own emergency preparedness programs and those of municipalities; the federal government’s role in emergency response on the ground is limited and they tend to focus more on terror/security concerns than natural or man-made emergencies (Grieve, 2013). The Canadian Red cross also plays a large role in the delivery of emergency response aid and programing in Nova Scotia, and the province has a formal agreement with the Red Cross to provide key services and donations management in the event of an emergency (Grieve, 2013). The province also mandates contingency planning for private industries and attempts to engage them in the broader emergency preparedness effort (NSERP, 2010). Nova Scotia’s EMO has a clear vision, “to be recognized by [Nova Scotian’s] for our integrity, innovate, and responsiveness in administering high quality emergency management programs, while encouraging intergovernmental and international partnerships for greater 28 governmental efficiency through effective mitigation, preparedness, response, and recovery strategies” (NSERP, 2010, p. 18). This vision embodies the ‘new’ paradigm of emergency management in so far as to recognize the importance of mitigation and recovery and to promote integration of multiple stakeholders in emergency planning. The EMO does not, however, explicitly connect emergency management to ideas of long term community planning nor sustainable development in the province. Private Industry Nova Scotia Environment Environmental Monitoring and Compliance Division Emergency Response Manual Muniscipal Government Nova Scotia Government Environmental Emergencies Response Plan Emergency Management Office Nova Scotia Emergency Response Plan Risk & Susceptibility Anlaysis Red Cross Federal Government Department of Justice Other Department's EP Business Continuity Management Program Emergency Management Act Fig 3: Nova Scotia’s emergency management system components including (shaded) outside actors, key departments and the sources of the documents analyses in this study. The two-sided arrows indicate information exchange and legislative relationships between actors. Emergency response protocols in Nova Scotia relate directly to the nature of the emergency, and within all departments of the Government of Nova Scotia, there is a Departmental Emergency Preparedness Officer (DEPO) who deals directly with planning for emergencies relating to the specific portfolio of that department. Environmental emergencies are managed by Nova Scotia Environment supported by other key departments like the Department of Energy, Natural Resources, and Public Health through Regional Environmental Emergency Teams (REET). The NSERP enumerates 20 emergency response actions for which NSE is 29 responsible (See Appendix x) including water supply monitoring, the development of in-house training programs, and the provision of technical personnel and advice to municipalities regarding pollution-vulnerable systems (2010). Safety & Environmental Officer Liasons Officer NSE Incident Command Center (Response Coordinator) Communications Officer Logistics Section Information & Business Services Technical Advisement Section Operations Section Applied Science & Sustainability Environmental Monitorng and Compliance ERP Planning Coordinators Field Assessment Units External Agency Support Figure 4: Schematic of the NSE Incident Response hierarchy. In the event of an environmental emergency, senior staffs designate a Response Coordinator who works with the DEPO and REET to establish an NSE Incident Command Center. NSE response functions are split into logistics, technical advisement, and response operations with additional safety, liaison, and public communications officers aiding the DEPO in overall response coordination (See Fig. 4) The Nova Scotia Environmental Emergencies Response Plan (2008) and Environmental Monitoring and Compliance Division Response Manual (2009) describe response protocols as they relate to various levels and classifications of environmental emergencies. 30 A tailings dam collapse would be classified as a large, potentially severe environmental emergency requiring a Level 3 land-based hazardous materials spill response. (NSE, 2009). NSE outlines three key steps to managing hazardous chemical spills noting that these particular events require extreme caution and coordination of outside resources (See Fig 5.) Specific procedural response steps for a hazardous materials release are not developed; rather, NSE refers to landbased oil spill protocols as sufficient guides. 1) Identification •Type of material •Quantity of materials •Type of packaging that has failed to contain the materials •Hazards posed by the material released 2) Evaluate Risks •Confirm the product •Confirm the hazard •Enact safety limits •Are first aid or safety officers required at the scene? 3) Coordinate Response •Ensure Person Responsible is taking ppropriate actions to stop the release and contain the spill, if not the NSE responder may iniate measures •Access and use needed equipment •Engage in communication Figure 5: Three step process outlined in the EMCDM to guide hazardous materials spill response. A tailings release would pose serious challenge for first-responders. Uncertainty regarding the contents and concentration of pollutants in tailings dams, their potential impacts, and the general extent of possible damage (which would rely on estimates of the volume and types of material released) make identification and evaluation of risks very difficult in practice. Minerals mining activities, for the most part, do not occur near urban centers – so, it is also important to take into consideration the time it would take to assemble temporary containment structures, testing equipment and staff at the site. If the spill were to occur at an inactive mine site, it is unlikely there would be swift containment response from the Party Responsible who would not have staff onsite. On the positive side, the documents examined did contain extensive resource lists and contact sheets for the speedy assembly of expertise and equipment. 31 5.2 System Successes and Gaps Thematic analysis of framework evaluations revealed several key insights into the areas of emergency management Nova Scotia succeeds in, where there are gaps, and the extent to which the system as a whole deals with environmental emergencies. It is important to reiterate in this discussion that, while program evaluation is a vital task for public managers, in an emergency management context the results of such are not absolute predictors of response effectiveness in the case of an emergency. Still, it is important to proactively identify aspects of the emergency management system that are lacking in terms of quality. Once identified, resources can be diverted to address these concerns. Established planning strategies, stakeholder relationships, and expertise used in the development of the high-quality aspects of Nova Scotia’s emergency system could be applied to these gaps. In addition, from a crisis response stand-point, knowing what aspects of the emergency system are stronger than others may aid in decisionmaking. 5.2.1 Successes Nova Scotia’s provincial emergency management system does an excellent job defining clear planning responsibilities and response command-chains, engaging critical service providers, and accounting for various emergency situations. In the event of an emergency, provincial officials have an accessible, well-laid out document to refer to in order to determine who the lead agency is, what the reporting relationships are, and what everyone’s responsibilities are. With both a staffed Emergency Management Office and Departmental Emergency Management Officers, The Government of Nova Scotia has set itself up to facilitate interdisciplinary planning and response functions, especially in the case of a severe emergency that triggers Joint Emergency Operations Center action. Clear command chains facilitate and prioritize response functions and decision-making in crisis situations, so this organizational clarity forms a solid foundation on which the rest of the emergency management system can stand. In addition, these command-structure documents deal explicitly with an array of emergency situations and levels of severity, adding both depth and breadth to the understanding of public officials tasked with crisis decision making. Lastly, another major success of Nova Scotia’s emergency management system is it’s collaboration with private sector businesses, particularly with key service providers like regional potable water services, telecommunications 32 providers like Bell, and Nova Scotia Power. While this study focuses on the preparedness and capacity of the provincial government, there are many more stakeholders that are considered emergency management actors; forging relationships and sharing resources before an emergency increases awareness and integration of emergency preparedness and response actions. EMONS reports that it has created resources for private businesses and that the private sector is actively engaged during the annual NS Emergency Response Plan review. 5.2.2 Gaps Where the current emergency management system in Nova Scotia succeeds in managerial clarity, it is lacking in terms of public engagement, mitigation planning, and recovery functions. Major public engagement criteria like volunteer management planning, community emergency response teams, public information planning, and public education are partially or completely unfulfilled by this system. Some of this may be attributed to the fact that these functions are simply not understood to be within the Government of Nova Scotia’s emergency preparedness mandate. In the event of an emergency that resulted in large numbers of donations and volunteers, the organizational responsibility may fall to the Red Cross or public communications officials within the lead agency. Community response teams may exist in regions around the province, but they are not formally recognized or managed by the provincial government. An explicit emergency communications plan was not found, but likely exists as part of general communications protocols and guides within the government. Public education is a critical task for emergency managers in order to make individuals aware of resources and emergency response procedures; this information should be accessible to all and ideally delivered or offered through workshops. Nova Scotia’s public education is limited to online resources which may not be accessible to many groups, especially vulnerable populations such as the elderly, visually or physically impaired individuals, and immigrants/refugees/low-income groups who may not speak English or have regular access to computers. In addition, the heavy reliance on online resource and information dissemination strategies is a risk; if an emergency causes telecommunication or power blackouts, most Nova Scotians would probably struggle to navigate the situation and find information. Mitigation planning is another ‘missing’ category. Hestra defined mitigation planning as “the effort of developing strategies to reduce vulnerability of people and property to hazards” 33 (2010). Ideally, the plan should relate to the local government’s own specific risks, define goals, and identify strategies to achieve them. In the documents analyzed, there was no explicit development of such a plan, nor were links between risk assessments, land-use planning, special needs planning, and infrastructure protection drawn together as ‘mitigation strategies’ – though, at least in the eyes of this researcher, that is what they are. This apparent gap may be more a result of what seems to be Nova Scotia’s attitude that all preparedness planning seeks, ultimately, to mitigate impacts, so a separate plan would be redundant. However, some effort could be put into drawing together the links more effectively, including developing links between climate change mitigation/adaptation works to emergency preparedness. Lastly, the Nova Scotian system lacks a well-developed recovery plan, particularly in the areas of debris management planning and community support. Much of the managerial effort Nova Scotia excels at ends abruptly with response functions, and very little clarity is given in terms of the short and long-term recovery efforts. One explanation for this may be that the recovery demands of one emergency to another are so different that expending resources to develop such a fleshed out plan would be impractical. Another explanation could be that Nova Scotia’s provincial agencies, in practice, transfer most of the recovery functions beyond damage assessment to municipal bodies. It may be that somewhere in the EMO or at NSE there exists resources that detail how best to handle, dispose of, and track debris after an emergency – particularly if said debris is hazardous. However, again, this information was not consolidated within the documents analyzed. Additionally, while the NSERP (2008) notes that the provision of psychosocial services post-emergency is a critical function of response, questions of who is to provide these services, to whom, and through what mechanism remain unanswered. Postemergency, social stability often suffers which can result in elevated crime rates, mental health issues, and political unrest which could be, ultimately, as costly as the initial emergency event, so planning for rehabilitation and recovery is crucial (Quarentelli, 1996). 5.3 Environmental Emergency Preparedness As there was no specific best-practices guideline or evaluation tool found to specifically address environmental emergency preparedness, it was necessary to superimpose a broad environmental emergency criterion onto the Hestra all-hazards evaluation framework. This method succeeded in teasing out a few nuances within the broader emergency management 34 system in Nova Scotia, but the results are far from the rigorously studied, well-researched implications derived from the original Hestra Framework. That being said, the exercises of incorporating the environmental criteria, with a specific hazard in mind, is still a useful one in terms of understanding the extent to which the Nova Scotia government has recognized and systematically planned for these particular emergency scenarios. Nova Scotia Environment’s Environmental Emergencies Response Plan and Environmental Monitoring and Compliance Monitoring Response Manual work together to address broad environmental emergencies related to pollutant releases and threats to water supply. These documents meet basic – but critical – emergency management requirements including having clearly laid out response command structures, defined emergency managers, mandates, training programs, and emergency public communications personnel. While emphasis in the NSE guidelines is on oil /petroleum releases, the procedures outlined in the documents are also applicable, at least in the eyes of NSE planners, to hazardous materials releases like tailings dam release. Particularly because NSE also is concerned with potential water pollution, which is a major implication of tailings dam failures, the tools currently developed within the emergency management system have the potential to give effective guidance to responders despite the uncertainties involved. However, as with the emergency management system in general, NSE has not explicitly expanded on mitigation strategies to protect people and property from pollutant releases and water contamination, nor has this mandate been explicitly connected to sustainable development. Efforts to mitigate and adapt to forces that influence the frequency of emergencies – environmental or otherwise – like climate change, population growth, and industrialization may exist within NSE or other Government of Nova Scotia departments, but they are not directly linked to emergency management. If the EMO and NSE wish to prepare for effectively for environmental emergencies in Nova Scotia, these issues should be addressed – ideally supported by a consultation process including other government actors, private businesses, and community stakeholders. 5.4 Limits of the Hestra Framework The process of the research unveiled a few important considerations on the limits and applicability of the Hestra Frame to the question of Nova Scotia’s emergency management 35 capacity. First, the framework itself was developed as a tool for local governments, specifically municipalities and small regions. While a few minor changes were made to the original criteria (see Appendix) in order to make the language specific to a provincial jurisdiction, it is likely that a few of the criteria like debris management and volunteer/donations management simply are not believed to be the responsibility of the provincial body. It could also be that, in practice, provincial responders have never felt the need or been faced with a situation that debris management and volunteer management needs exceeded the scope of municipal or private response teams. A more precise evaluation would require a complete adaptation of several of the criteria based on the provincial emergency management responsibilities as outlined by the Emergency Management Act (2005). Overall, there were only a few instances where there seemed to be jurisdictional inconsistencies. One of the other limits of the Hestra Frame, more generally, is its broadness and simplicity as an evaluation tool. While this can be viewed as a strength from the perspective of a program evaluator who has few resources, access to expertise, or specific research to provide a more complex system evaluation it is also a weakness. There were a few instances were certain criteria if allowed a more nuanced scoring scheme or description would not have received full points as they did in this Adapted Hestra Frame evaluation. Specifically, the preparedness criteria training and special needs planning fulfilled the Hestra requirements to offer emergency training to auxiliary staff and to engage in planning for vulnerable groups respectively. While Nova Scotia has a developed training regimen divided by different levels of emergency response responsibility, the frequency of re-testing or re-certification in these training programs is not considered by the Hestra Frame. While it is not realistic to expect full-scale training and exercises to be carried out on a yearly basis for management staff, there is no actual requirement for senior emergency policy staff to recertify in this training. Instead retraining occurs on a recommended 5 year time scale (NSSERP, 2008). It occurs to me that this should probably bear some weight in terms of the quality score of training as a criterion in the Hestra Frame as emergency response protocols shift as positions and contact information changes, departments are renamed, mandates are redefined, and as emergency plans are updated. Another criterion that deserves some discussion is that of special needs planning. While the EMO has effectively identified vulnerable populations and the hazards to which they are most vulnerable in the Risk and Susceptibility Analysis (2010), the NSERP notes explicit 36 consideration only of individuals with disabilities and only in the context of evacuations (2008). Critical populations identified in the Risk and Susceptibility analysis include children (newborns, day-care populations, schools, etc.), university populations, and the ill (hospital patients, drugdependent or immunosuppressed individuals, diabetics, etc.) with a notable absence of recentimmigrants or refuge populations (though it might be assumed, imperfectly, that these are rolled into the category of ‘language limited’ individuals). Again, as in throughout this study, it is possible that planning for these populations exists, but it is not explicitly tied to the emergency management framework explored here. If planning for these populations does not exist, Nova Scotian emergency managers may find it difficult to communicate effectively with and mitigate the impacts on these populations. 5.5 Opportunities for Future Research There are several possible avenues for continued research in this area. Similar framework evaluations could be conducted across a wider sample of Canadian provinces in order to discern and compare broader preparedness and emergency management trends in Canada. Within Nova Scotia, a more details evaluation could systematically attempt to evaluate preparedness within individual regions of the province based on municipalities or regional planning teams. Qualitative interviews of emergency managers in the province could tease out more nuance in terms of how planning resources are (or aren’t) used in cases of crisis, how they are reviewed and improved, and how they are received by various levels of government. These interviews, or a separate study itself, could attempt to explore the attitudes of emergency managers at a given level towards environmental emergencies. Many of these designs could also be applied to emergency management professionals working outside public service or with health and safety managers in the private sector. Furthermore, addition research into the broader integration of knowledge between engineering, public policy, environmental science and public health academics would help to proactively define a specific sub-field of environmental emergency management. As it stands, it seems environmental emergency research, including this study, emerges primarily in response to crisis situations. I echo concerns identified by other authors about the lack of public information around and monitoring of tailings dams. In the Rico, et al. study, Canadian cases were simply excluded due to lack of reliable, accessible information. The task of compiling and reporting 37 information about process water contents, rates of tailings failures, causes, responses, and impacts is a massive one, but it is critical if we hope to gain an understanding of mining risks, population vulnerabilities and effective mitigation strategies CHAPTER SIX: CONCLUSION Mining is likely going to continue to be a contributor to Nova Scotia’s economy, and as we continue to change our climate, gather in urban areas, and invest in sustainable development priorities, it is crucial to recognize the opportunity to integrate emergency management planning into decision making processes. Nova Scotia is in a good position; the provincial government and it’s agencies administer a medium-high quality emergency management system that meaningfully addresses aspects of all four major phases of emergency planning – preparedness planning, mitigation, response, and recovery. In the case of an environmental emergency, the clearly defined lead agency, Nova Scotia Environment, possesses the resources, mandate and capacity to both respond to and plan for threats to water quality and releases of pollutants. Where work could be done to address more he unique challenges of events like a tailings dam release, the overall conclusion is that Nova Scotia would have the capacity to effectively respond to and manage such an environmental emergency. There are gaps in the system though, and, more problematically for the advocates of the ‘new’ emergency management paradigm, Nova Scotia does not conceptualize emergency management as a community development task. Rather, emergency management documents are very contained within the framework of the Emergency Management Act and the departmental requirements of the Emergency Management Office. While there is a great deal of intergovernmental expertise and information exchange indicated, these exchanges are focused solely on how to plan more effectively a more effective response. The Nova Scotia Government, it’s Emergency Management Office, and Nova Environment should recognize that the stakeholder communication and interdisciplinary government networks required to integrate emergency management explicitly into sustainable community development already exist via tasks such as business continuity planning, training and plan reviews. These networks should be exploited for the improvement of the system to this end. 38 Ultimately, the purpose of this research was not to address the broader concerns around sustainable mining or to critic Nova Scotia’s regulatory capacity in this industry; rather, it was to assert that failures happen and that we should be prepared for them. If we do not, we are essentially blindly charging into risky situations without containment or escape plan. In the context of a hazardous release, the potential for long-term devastating environmental consequences is greater without the clear response protocols, chains of command, and training that constitute preparedness. Hopefully, Nova Scotia, the EMO, and NSE will continue to engage with the struggle of emergency management planning, seek out ways to improve their mitigation strategies, and integrate their work into the broader task of ensuring all Nova Scotians have the opportunity thrive. 39 REFERENCES Baker, P. (2014, August 4). Residents calling it an environmental disaster: tailing pond breach at Mount Polley near Likely, Bc. Global News, pp. http://globalnews.ca/news/1490361/tailings-pond-breach-at-mount-polley-mine-nearlikely-bc/. Bazerman, M., & Watkins, M. (2004). Predictable Surprises: The Disasters You Should Have Seen Coming and How to Prevent Them. Harvard Business Press. Beatley, T. (1995). Planning and sustainability: a new (improved?) paradigm . 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(1990), “Local Government’s Problems with Disaster Management: A Literature Review and Structural Analysis,” Policy Studies Review, 8: 42 703-725. Wolf, S. (1996). Fear and Loathing about the Public Right to Know: The Surprising Success of the Emergency Planning and Community Right-to-Know Act. Journal of Land Use and Environmental Law, 11(2), 218-312. 43 APPENDICES Appendix 1: Hestra Framework (2010) 44 Appendix 2: Hestra Criteria descriptions All criteria descriptions are quoted from Hestra (2010). Adaptations to these definitions are noted in italics and confined to issues of government scale.. Preparedness policies 1. Emergency manager – professional individual or secondary function of governing official; involves coordinating the activities of many actors, both within the local government and in the broader community who plays a key role in setting policy objects and draws together community resources to implement them. 2. Emergency management program committee – effective response requires all relevant actors to be aware of their duties and endorse the objectives of the emergency management program. Periodic meetings can generate support for emergency management as a continuous process. 3. Hazard and risk identification – officials must may choices about where to allocate scarce resources, by identifying hazards that threaten the community and evaluating the risks they pose, managers formulate appropriate response strategies. Three levels of sophistication exist for this task (1) hazard identification, (2) vulnerability assessment, and (3) risk analysis. 4. Emergency response plan – most basic preparedness element, which serves as an operational manual for crisis decision making 5. Plan Review - yearly reviews to keep current. 6. Emergency management provincial legislation (changed from by-law to reflect scope) shows commitment from a governing body to its constituents that disaster preparedness is a top priority. 7. Training – training teaches actor about their expect roles during an emergency and the difficulties they are likely to encounter. Training should be provided, at minimum, to key elected officials and departmental heads responsible for decision makings during an emergency, but may also be extended to auxiliary staff and volunteers. 8. Exercises – three different types of exercises can be distinguished; (1) table top, (2) functional and (3) full-sale. These exercises help to detect and diagnose program weaknesses through the simulation of an emergency. 45 9. Mutual aid – prudent for provincial government to establish mutual aid agreements with other levels of government (changed from ‘neighboring communities’ to reflect scale) whereby they can draw upon equipment and personnel if their own capacity is overwhelmed. 10. Critical infrastructure protection – effort has been made to assess the vulnerability of critical infrastructure systems – electrical power transmission, telecommunication -- which, if disrupted, could seriously threaten the health, safety and security of citizens. 11. Planning for people with species needs – managers must consider the needs of vulnerable groups who are especially susceptible to hazards. 12. Business engagement – industry actors should be engaged in planning for these events as they may have direct impact on the success of their business. Mitigation 13. Mitigation plan – effort has been put into developing strategies to reduce vulnerability of people and property to hazards; the plan must specify local government’s mitigation goals and identify short/longterm strategies to achieve them. 14. Warning system – citizens are key in emergency response, so there must be a warning systems in place through which emergency managers have means of communicating with citizens. 15. Public education – fosters sense of responsibility and raises general awareness of emergency planning which can help people respond to emergencies. 16. Dangerous goods routing – vehicles carrying hazardous substances are a risk for most communities; specified routes for these vehicles allows for special protective measures to be put in place and public education targeted at those who live in the area. 17. Risk-based land-use planning – key mitigation tool; refers to restrictions that limit the exposure of people and property to hazards caused by development. Response Policies 18. Emergency operations center (EOC) – prearranged location from which officials can coordinate and communicate with responders, other levels of government, and the public. This is the hub for coordinating and deploying resources in the event on an emergency. 46 19. Incident management system – prearranged coordination scheme that outlines clearly a chain of authority encompassing diverse organizations in the event of an emergency 20. Evacuation plans – criteria which help decision makers understand when, how and who to evacuate in the case of different emergencies. 21. Emergency shelter arrangements – planning for shelter in cases of major emergency – particularly one which requires evacuation – is important. It is advisable to work with experience non-governmental agencies who have experience in this kind of coordination. Shelter planning must occur at various scales (shelter for 10 individuals verse thousands) 22. Volunteer management – Experience with large scale disasters has shown that emergent volunteers are a powerful resource in emergency response and that preemptive planning for coordination and management of these volunteers can increase their effectiveness. 23. Community emergency response teams (CERTs) – trained groups of volunteers which perform a number of important response functions such as first aid, light search and rescue, communicating field intelligence to the EOC. 24. Search and rescue – Planning for this function, often performed by volunteers, includes establishing guidelines for activities such as debris searches and technology deployment. 25. Emergency public information – A developed emergency communications plan is key to advising and protecting citizens. Recovery Policies 26. Recovery Plan – Advance planning of actors performing recovery functions may establish partner organizations and assign supervisory roles of officials or subcommittees 27. Continuity of operations planning – Planning for the continuity of critical government functions and services during recovery phase; developing strategies to restore them if they are interrupted in an emergency 28. Damage assessment – Provisions for information collection, dissemination, financial resources/assistance protocols and building-weakness documentation should be included as part of an emergency management program. 29. Debris management – critical short term recovery priority, particularly is debris is blocking roads connecting key facilities like hospitals. 47 30. Rehabilitation – pre-planning for psychological counseling and mental health rehabilitation programs for victims/responders mitigate potential increases in stress related violence – particularly domestic violence and suicide - post-emergency 48
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