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California Is Not Adequately Prepared to Protect Its Most Vulnerable Residents From Natural Disasters


Report Number: 2019-103


Audit Highlights . . .

Our audit of three counties assessing their emergency planning to protect vulnerable populations before, during, and after natural disasters revealed the following:

Results in Brief

In recent years, California has experienced an increase in the frequency and destructive nature of wildfires. Experts predict that the recent trend of increased frequency and severity of wildfires will continue, requiring the State to be prepared to protect its residents more often from more dangerous natural disasters than it has in the past. The State's emergency management system designates local governments—such as counties—as primarily responsible for emergency preparedness and response. In that role, the local governments should develop emergency response plans (emergency plans) that adequately prepare them to protect all residents, including the most vulnerable. We reviewed the extent to which three counties'—Butte County (Butte), Sonoma County (Sonoma), and Ventura County (Ventura)—emergency planning incorporated best practices and the effect that not following those best practices had on their responses to recent wildfires. We determined that the counties have not adequately followed key practices for emergency planning, including having emergency plans for alerting, evacuating, and sheltering residents and assessing the needs of their communities in advance of disaster events. As a result, the counties are less prepared for future natural disasters, which may place the residents for whom they are responsible at greater risk of harm.

In particular, the three counties have not adequately prepared to protect people with needs that cannot be met by traditional emergency response and recovery methods. Within the emergency management community, those needs are referred to as access and functional needs. Under state law, people with access and functional needs include, among others, older adults and people with disabilities, chronic conditions, temporary injuries, and limited English proficiency. Although everyone is vulnerable during a natural disaster, people with access and functional needs are even more vulnerable. As a result, these individuals have historically been disproportionately affected by natural disasters. The United Nations reports that people with certain access and functional needs are more likely to die from these events. During past events, emergency response agencies have struggled to assist them. 

However, none of the counties we reviewed have implemented key best practices from the Federal Emergency Management Agency (FEMA) and other organizations to ensure that their emergency plans fully address the access and functional needs of the people in their communities. These practices include involving representatives of people with such needs in the emergency planning processes. These representatives are best positioned to provide insight about how counties can effectively meet access and functional needs during a natural disaster. Despite this valuable perspective, none of the three counties adequately engaged with representatives of individuals with a variety of access and functional needs in their community when developing their emergency plans.

We recognize that no amount of planning or preparation will guarantee success during a natural disaster. This is particularly true when the natural disaster is historic in size and scope, as has been the case in each of these three counties in the past two years. Each county we reviewed recently experienced wildfires that were among the most destructive or deadly in the history of California—the 2018 Camp Fire in Butte, the 2017 Sonoma Complex Fires in Sonoma, and the 2017 Thomas Fire in Ventura. Moreover, determining if any additional lives would have been saved during these events if the counties had planned differently or more fully implemented best practices is impossible, and we reach no conclusion to that effect. In fact, FEMA acknowledges that using a prescribed planning process cannot guarantee success. However, it also notes that inadequate plans and insufficient planning are proven contributors to failure. Therefore, deficiencies in a county's efforts to prepare for a natural disaster can impair its ability to respond when the disaster occurs.

For example, each county lacked a completed, updated plan for issuing evacuation warnings and each had deficiencies in the way it issued warnings to the public during these historic disasters. During those wildfires, none of the counties issued warnings directing people to evacuate in languages other than English. As a result, some people likely did not receive potentially life-saving emergency information in a language that they could understand. Moreover, despite having access to technology that could reach all cell phones in their evacuation zones, Butte and Sonoma did not send alerts using that technology. Instead, both counties sent messages through notification systems that reach landlines and reach a person's cell phone only if that person has preregistered to receive emergency alerts from the county.

Further, we identified similar deficiencies in the three counties' preparedness for evacuating and sheltering people with access and functional needs. FEMA's best practices state that counties should assess what resources they will need to assist such people during evacuations and sheltering. These resources include accessible transportation options for evacuation assistance and accessible cots, showers, and toilets for emergency shelters. According to best practices, counties should ensure that those resources will be quickly available during natural disasters by prearranging agreements with vendors or other organizations, yet none of the counties we visited have established a full set of agreements for those resources. Butte has established several agreements for shelter resources, but it lacks any prearranged agreements for transportation to assist evacuation. Similarly, Sonoma and Ventura have no prearranged agreements for transportation and lack key agreements for shelter resources.

Some of the deficiencies that we found at the counties—such as not having evacuation plans or not issuing effective alert and warning messages—affect all their residents, not just those with access and functional needs. As natural disasters grow in severity and frequency, the potential effects of being underprepared also grow. Therefore, it is critical that the State also do more to ensure that local jurisdictions are as prepared as possible. Unlike in California, state laws in Florida and Texas require their state emergency management division to establish standards for and periodically review local jurisdictions' emergency management plans. A similar requirement in California could direct the California Governor's Office of Emergency Services (Cal OES) to review and provide feedback to local emergency management agencies on the extent to which their plans effectively incorporate emergency management best practices, especially related to protecting and assisting people with access and functional needs.

Cal OES is the State's lead agency for emergency management, and its mission is to protect lives and property, build the State's emergency response capabilities, and support communities. Although Cal OES has issued some guidance and tools for assisting local jurisdictions in developing emergency plans to meet access and functional needs, it has not done enough to fulfill its mission with respect to protecting these vulnerable populations. Specifically, Cal OES has not taken key steps to provide support to local jurisdictions.

First, Cal OES has failed to provide important resources to help local jurisdictions in planning, even when state law has required it to do so. For example, Cal OES has not complied with state law requiring it to provide guidance to local jurisdictions related to strategies for identifying people with access and functional needs and for evacuating people with disabilities. As a result, local jurisdictions—like those that we reviewed—may struggle to adequately plan for how to best assist those people. Until Cal OES complies with the requirements in state law, it will not have fulfilled its purpose of providing support and technical assistance to local jurisdictions as they plan for disasters.

Additionally, Cal OES has not followed best practices for involving people with access and functional needs in developing its own plans and guidance. Instead of including representatives of such persons in developing its guidance documents, Cal OES relies on a single individual—the chief of its Office of Access and Functional Needs—to inform its guidance. As a result, the guidance it recently released on alerting and warning did not feature strategies or specific guidance for how to alert people with hearing impairments. Local jurisdictions rely on Cal OES's plans and guidance to determine how to conduct their own planning. If Cal OES's plans and guidance do not fully address access and functional needs, local jurisdictions' plans may not either.

Finally, Cal OES has not disseminated after-action reports that include lessons learned from natural disasters to help local jurisdictions learn from the successes and mistakes of others. Implicit in Cal OES's mission to protect lives, build capabilities, and support communities is a responsibility to identify and take proactive steps to correct problems in emergency management that may jeopardize the lives of residents, including those with access and functional needs. Despite a state law requiring Cal OES to issue after-action reports within 120 days of the end of a disaster, the most recent disaster for which it has completed an after‑action report occurred in February 2015, and it did not complete that report until May 2019—more than four years after the disaster occurred. As a result, it has missed an opportunity to assist local jurisdictions in adapting their plans based on the lessons learned by other jurisdictions.

Summary of Recommendations


The Legislature should require Cal OES to review all counties' emergency plans to determine if they are consistent with best practices and provide necessary technical assistance to counties.

The Legislature should require Cal OES to involve organizations representing individuals with a variety of access and functional needs in the development of the state emergency plan and guidance for local jurisdictions and to annually disseminate guidance based on lessons learned from natural disasters.


To ensure that they are adequately prepared to protect vulnerable populations during a natural disaster, each county should revise its emergency plans by following best practices for planning to meet the access and functional needs of its residents, including involving people with those needs in its planning process and developing strategies for alerting, evacuating, and sheltering them.

To ensure that its future emergency planning efforts more fully address access and functional needs, each county should adopt county ordinances that require it to adhere to the best practices and guidance issued by FEMA, Cal OES, and other authorities when conducting such planning.


Cal OES should, by no later than June 2020, issue the guidance related to access and functional needs to local jurisdictions that state law requires it to produce.

Agency Comments

Each of the counties expressed concerns about our conclusions that they are not adequately prepared to protect vulnerable populations and that inadequate preparation affected their response to recent wildfires. Neither Butte nor Ventura consistently indicated whether they plan to implement our recommendations. Sonoma generally agreed with our recommendations. Cal OES strongly disagreed with our conclusion that it has not adequately supported local jurisdictions in planning to meet access and functional needs and indicated that it would not fully implement our recommendation to provide all of the guidance that state law requires it to provide to local jurisdictions.

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