Many utilities invest time in their Emergency Response Plans, yet recurring gaps still weaken real-world response. The issues below are the ones we see most often across the industry.

1. Treating it as a compliance document, not a living plan: Plans are written once (often for EPA or state compliance) and then put on a shelf. They aren’t updated with new threats (e.g., cyber, climate extremes, supply chain). They don’t reflect changes in staff, assets, or interconnections.

2. Failure to involve the right stakeholders: Written only by management or consultants with a lack of employee participation—operations staff, IT/OT, communications, and customer service often aren’t included. External partners (e.g., fire, police, public health, mutual aid networks) aren’t engaged until an actual incident.

3. Plans are too generic or boilerplate: Language is copied from templates and lacks system-specific detail. Doesn’t include clear operational triggers (“when do we switch to manual ops? Who authorizes changes in operation?”). Overly long and theoretical, not practical for field staff during an emergency.

4. Unclear roles and responsibilities: Incident Command System (ICS) roles not clearly assigned and staff lack adequate training to fulfill these roles. No backup personnel identified if key staff are unavailable. Decision-making authority (e.g., who can declare an emergency, authorize public notices, or request outside aid) is fuzzy.

5. Poor communication planning: Outdated or missing contact lists (e.g., staff, contractors, regulators, media). No protocols for public messaging (e.g., how to quickly notify customers about boil water, sewer overflows, etc.). Lack of coordination with city/county Joint Information Systems (JIS).

6. Underestimating cyber and technology risks: ERP focuses heavily on natural hazards (e.g., storms, floods) but skips cyber disruptions. No contingencies for loss of SCADA, telemetry, or billing systems. IT/OT subject matter experts often not integrated into response structure.

7. Insufficient attention to supply chain and vendor dependencies: No backup contracts for fuel, chemicals, lab services, or critical parts. Single points of failure in chemical supply or critical facilities not addressed. Reliance on “normal” delivery schedules without alternate plans.

8. Unrealistic or untested procedures: Plans assume resources (e.g., staff, generators, fuel, contractors) and capabilities (e.g., bypass valve, interconnection, site access) will be available immediately. No practice in implementing mutual aid agreements (WARNs). Recovery and continuity procedures (return to service, regulatory reporting, additional worker shifts) are vague or missing.

9. Inadequate training and exercises: Staff are unfamiliar with the document or their role in it. No after-action review process to fix weaknesses revealed in drills or real events.

10. No integration with broader resilience planning: ERP isn’t aligned with Risk & Resilience Assessments (RRAs), hazard mitigation plans, or city/county emergency management plans. Risks aren’t prioritized and response plans aren’t risk-based. Utility ends up siloed or crippled in a crisis- duplicating efforts, competing for resources, or left only with regrettable options.