Report 2019-103 Recommendation 9 Responses

Report 2019-103: California Is Not Adequately Prepared to Protect Its Most Vulnerable Residents From Natural Disasters (Release Date: December 2019)

Recommendation #9 To: Sonoma County

To ensure that the county's emergency planning efforts more fully account for people with access and functional needs in the future, the county should adopt county ordinances that require the county's emergency managers to do the following during each update to the county's emergency plans: when planning to protect people with access and functional needs, adhere to the best practices and guidance that FEMA, Cal OES, and other relevant authorities have issued; report publicly to the boards of supervisors during emergency planning about the steps they have taken to address access and functional needs; consult periodically with a committee of community groups that represent people with a variety of access and functional needs; require that representatives of the community group committees present to the board of supervisors their review of the adequacy of the emergency plans.

Annual Follow-Up Agency Response From September 2023

The County of Sonoma has adopted a policy that the Director of Emergency Management report publicly to the Board of Supervisors during emergency planning about the steps taken to address access and functional needs. The County of Sonoma has implemented a policy that the County consult periodically with a committee of community groups that represent people with a variety of access and functional needs and to request that representatives of the community groups committee present to the Board of Supervisors their review of the adequacy of the emergency plans. The County of Sonoma does not agree with the recommended process for implementing the recommendations. Best practices, by definition, are reliant upon the specific facts and circumstances of a situation and formalizing these steps into local law does not create the type of flexibility needed in responding or planning for a disaster response. In May 2020, the Board of Supervisors adopted policies that implement the above which provide a better mechanism to improve and expand upon them as state standards and best practices change, rather than more formalized and time intensive amendments to local ordinances.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

There has been no change since Sonoma County's previous update. As we have stated previously, we continue to believe that an ordinance would be a stronger commitment to planning to protect people with access and functional needs.

Annual Follow-Up Agency Response From October 2022

The County of Sonoma has adopted a policy that the Director of Emergency Management report publicly to the Board of Supervisors during emergency planning about the steps taken to address access and functional needs.

The County of Sonoma has implemented a policy that the County consult periodically with a committee of community groups that represent people with a variety of access and functional needs and to request that representatives of the community groups committee present to the Board of Supervisors their review of the adequacy of the emergency plans.

The County of Sonoma does not agree with the recommended process for implementing the recommendations. Best practices, by definition, are reliant upon the specific facts and circumstances of a situation and formalizing these steps into local law does not create the type of flexibility needed in responding or planning for a disaster response. In May 2020, the Board of Supervisors adopted policies that implement the above which provide a better mechanism to improve and expand upon them as state standards and best practices change, rather than more formalized and time intensive amendments to local ordinances.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As we note under Recommendation 3, Sonoma has completed its update to its emergency plans, which is positive progress. Nonetheless and as we have stated previously, we continue to believe that an ordinance would be a stronger commitment to planning to protect people with access and functional needs.

Annual Follow-Up Agency Response From October 2021

The County of Sonoma's successful responses to the 2019 Russian River Flood, the 2019 Kincade Fire, the 2020 LNU Lightning Complex Fire, and the 2020 Glass Fire demonstrate that much of the substance of this recommendation has already been implemented. The County has refined its policies and emergency plans to include adoption of applicable guidance and FEMA, Cal OES and other relevant best practices. The County looks forward to incorporating statewide standards into its updated emergency plans and working with the State as a partner in developing these important guidelines.

The County of Sonoma has adopted a policy that the Director of Emergency Management report publicly to the Board of Supervisors during emergency planning about the steps taken to address access and functional needs.

The County of Sonoma has implemented a policy that the County consult periodically with a committee of community groups that represent people with a variety of access and functional needs and to request that representatives of the community groups committee present to the Board of Supervisors their review of the adequacy of the emergency plans.

The County of Sonoma does not agree with the recommended process for implementing the recommendations. Best practices, by definition, are reliant upon the specific facts and circumstances of a situation and formalizing these steps into local law does not create the type of flexibility needed in responding or planning for a disaster response. In May 2020, the Board of Supervisors adopted policies that implement the above which provide a better mechanism to improve and expand upon them as state standards and best practices change, rather than more formalized and time intensive amendments to local ordinances.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As we have stated previously, an ordinance would be a stronger commitment to planning to protect people with access and functional needs during emergencies. Sonoma provided its formalized policy, which requires that it incorporate best practices into its planning, involve community groups representing people with access and functional needs, and report publicly on steps taken to address those needs. Sonoma's policy could be effective if Sonoma fully implements it; however, Sonoma has not completed updating its emergency plans, rendering us unable to fully assess Sonoma's implementation. When Sonoma finishes updating its emergency plans, which it stated it will do by January 2022, we will reevaluate Sonoma's implementation of this recommendation.

1-Year Agency Response

The County has fully implemented this recommendation by adopting a policy that requires the Director of the Department of Emergency Management to take the following actions in the development of emergency plans:

Incorporate within the County of Sonoma's emergency plans applicable best practices and guidance from the Federal Emergency Management Agency, the California Office of Emergency Services, and other relevant authorities; and

Report publicly to the Board of Supervisors during emergency planning about the steps taken to address persons with access and functional needs; and

Consult periodically with a committee of community groups that represent people with a variety of access and functional needs, and request that the representatives of the community groups committee consulted in the development of emergency plans present to the Board of Supervisors their review of the adequacy of the emergency plans.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

As we stated after Sonoma's six month update, an ordinance would be a stronger and more appropriate commitment to planning to protect people with access and functional needs during emergencies. We will not consider this recommendation to be fully implemented until Sonoma enacts the ordinances we describe in the recommendation.

6-Month Agency Response

The County has fully implemented this recommendation by adopting a policy that requires the Director of the Department of Emergency Management to take the following actions in the development of emergency plans:

Incorporate within the County of Sonoma's emergency plans applicable best practices and guidance from the Federal Emergency Management Agency, the California Office of Emergency Services, and other relevant authorities; and

Report publicly to the Board of Supervisors during emergency planning about the steps taken to address persons with access and functional needs; and

Consult periodically with a committee of community groups that represent people with a variety of access and functional needs, and request that the representatives of the community groups committee consulted in the development of emergency plans present to the Board of Supervisors their review of the adequacy of the emergency plans.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

We recommended that Sonoma incorporate these requirements into an ordinance to give those requirements the effect of law. However, Sonoma did not do so. Instead, Sonoma's board of supervisors formally adopted a policy incorporating the elements of our recommendation. Because of the importance of these best practices, an ordinance would be a stronger and more appropriate commitment to planning to protect people with access and functional needs during emergencies. We will not consider this recommendation to be fully implemented until Sonoma enacts the ordinances we describe in the recommendation.

60-Day Agency Response

The County of Sonoma's County Counsel's Office, in conjunction with the Department of Emergency Management, is currently drafting policies that (1) require adoption of applicable guidance from FEMA, Cal OES and other relevant best practices; and (2) that the Director of Emergency Management report publicly to the Board of Supervisors about steps taken to address access and functional needs during emergency planning.

The County of Sonoma will continue implementing its policy to consult periodically with a committee of community groups that represent people with a variety of access and functional needs, and to request that representatives of the community groups present to the Board of Supervisors their review of the adequacy of the emergency plans.

The County of Sonoma does not agree with the recommended process for implementing this recommendation, and will adopt the recommended actions as policies rather than ordinances.

California State Auditor's Assessment of 60-Day Status: Pending

Sonoma states in its response that it will adopt policies rather than county ordinances. We recommended that the county adopt ordinances requiring that the county follow emergency planning best practices because of the importance of those best practices. An ordinance would be a stronger and more appropriate commitment to the best possible emergency planning because an ordinance would make that commitment a legal requirement. We will not consider this recommendation to be fully implemented until Sonoma enacts the ordinances we describe in the recommendation.

All Recommendations in 2019-103

Agency responses received are posted verbatim.