ICS and How it's Being Applied

Trying to better understand comments about the "bastardization" of the ICS on some fires.


Groups are functional units and Divisions are Geographic. Im unsure why they have the divisions going counterclockwise though.

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I understand the differences between the two, what I was unsure of is why the counterclockwise assignment. Seems like it would lead to confusion since every other incident organizes divisions clockwise. I’m also not a huge fan of intermixing groups and divisions unless it’s absolutely necessary. The worst example is “structure protection group” operating amongst various divisions. Give the DIVS the resources they need to handle the management and control objectives as outlined by the IC and Ops. Anyways, I’m getting off topic of the Q&A thread, so back to the normally scheduled program. Thanks!


I understand and share your frustration!


Continued bastardization of the Incident Command System (ICS) only ruins the design of the System… How can we continue to preach the all-hazards importance of ICS if those who don’t know or don’t care about the System design do what they want? Crazy. Unnecessary.


FireHawkC3100, Ff13, FireBCKev; Can you further explain what you mean by the bastardization of ICS? The counter-clockwise application or the discussion about Divisions and Groups? I am curious about folks ideas. To keep this thread clean I have a topic in the General Discussion Section.

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Structure groups make perfect sense and it was a mistake to suggest removing them during the building of the WUI standards. If you are going to remove structure groups, why not remove firing groups? Arguably there have been many more issues with firing groups than structure groups.
What happens when a large fast moving fire moves through a community and moves far beyond it. That area was initially a division, but now the geographical location of the perimeter is several miles beyond the community and the community is still burning and needs attention, most likely for multiple operational periods? That is where a structure group works.
What about community that has a large fire approaching it? The division is working to control the perimeter. The structure group is preparing the community. Once the fire hits the structure group can remain intact or roll into the division. Contingency groups should remain not involved in direct firefighting… hence the name contingency.
Groups have had to be used where two different IMT’s are working the same ground. If one IMT has already established divisions and branches, but are not able to adequately protect the values at risk and the second IMT brings in large amounts of resources to assist, but wants to retain leadership of those resources to ensure the mission is completed, groups need to be formed to reduce confusion on the ground while maintaining unity of command.
My guess is the change of clockwise vs counter clockwise is just a mistake…
As far as a previous discussion if a teams plan can fail… yes it can.
If a team cannot produce an accurate map, cannot support an incident logistically, or continues to state one plan, but then on the ground… the plan is not carried out that would be considered a failure.
The plan has to take into account the confluence of weather, fuels and topography. The goals should be achievable, and based on probability of success and must take into account resource capability. The OSC must validate that the plan they are putting out is carried out. There is a significant difference between the two agencies who have IMT’s… One utilizes a top down model where the OSC works through the OPBD to the DIV/GRP.
The other works from the bottom up, where specialized units create the plan, and it is passed back up to the OSC for implementation. That is the reality…


My thoughts but first please reflect 1981-12-12-ICS-120-1.pdf (2.0 MB) back the original ICS FIRESCOPE document, 1981-12-12-ICS-12011, Operational System Description and the defined components of ICS:

  • Common Terminology
  • Modular Organization
  • Integrated Communications
  • Unified Command Structure
  • Consolidated Action Plans
  • Manageable Span-of-Control
  • Predesignated Incident Facilities
  • Comprehensive Resource Management

In my eyes, bastardization might be to the words of the Incident Command System or might be a local adaption to the functioning of the ICS at a particular emergency.

Reversing the circular order of branches and divisions may have been a mistake as was just posted. Then again, it may have been an oversight that any good PSC should have caught and corrected. Is such a basic error that to accept it is perpetuating normalization of deviance. Would justify an ‘F’ Grade in S-420 or S-520.

This Fire Year 2021 has seen a proliferation of throwing a pool of resources into an area without tactical objectives with the idea that they will do what they can. This is contrary to proper tactical planning and an avoidance of responsibility on behalf of many fire organization players up to and including the Incident Commander. When the ground resources arrive at the reporting location and the DIVS briefs them-if he/she can based on limited intel just immediately arriving at the scene-what is the then necessary tactical connect with air operations who will be inbound and not know the laissez-faire tactical planning and execution. Divisions were designed within the ICS to accomplish geographical work and Groups to accomplish functional work.

Structure Defense Groups or Firing Groups are legitimate adaptations of functional tactical activities. What is important is that they function under the Consolidated Action Plan (IAP) for the particular operational period. As alleged, several instances of rogue firing has occurred during this Fire Year 2021. Such is a bastardization of the current applicable IAP.

Frankly, to the best of my knowledge, the utilization of the informal Planning Ops position is not recognized within either the NWCG or FIRESCOPE Field Operations Guides (FOG). Although the position works when appropriately utilized, acceptance within the formal ICS structure has never been authorized. I have learned to accept the aberration although I must mention it when asked about examples of bastardization.

On the note of ICS Common Terminology and although not big differences in most cases, the NWCG FOG and the FIRESCOPE FOG don’t jive. Some may jump on me about California being out of step with everyone else. I just counter with a smile, we built the system and wrote the book. I played a big role in that effort being the lead author for the original ICS S-430 OSC Training Class and subsequent FIRESCOPE revisions of the same training package.

Lastly, although I could mention more differences from ICS policy, I must mention how interagency differences create serious safety and operational differences under the ICS Components, Consolidated Action Plans. That is where one agency does one thing and another agency does another tactical action. Bad. Example: 2020 Northern California where two different teams were assigned. One was a federal team and the other a state team. They both without seemingly conferring with each other assigned the same piece of ground as a division within each’s IAP. Troops arrived from both organization on the ground and found each other present. They asked what are you doing here? Huh, what are you doing here? The teams created different FAR 135 restricted areas. How can we allow such aberrations of ICS? Why didn’t the ICT1’s confer with each other? Why was an effective ACA not present to oversee such a failure?

I have always believed in the following, “It is our job to maximize our similarities and minimize our differences.” That includes making ICS work for us but within the operating system boundaries created by and for the importance of ICS.

Now to this point, I have not recited my credentials with this post because my background is not the point of the post. Let there be no question that I am trained and qualified to perform today and without being a braggart do a damn good job. This is not a slam at IMT_Geek as I well know and respect his credentials and accomplishments and appreciate him asking me to articulate my beliefs about the bastardization of ICS.

Thank you very much. Best wishes and good health to all.


And coincidentally (consequently?), wasn’t there a fatality on that Division that operating period? Same piece of ground, with two different Division names, (edit: different tac channels on two 205’s as well) and I believe different boundaries as well. There was a lot of complexity in southwest Tehama County for about 48 hours.

Firefighter Diane Jones 8/31/2020


Norcalscan, yes that was a very complex situation that unfolded quickly although fire leaders had several days of advance notice of the impending fire hit. We must react quickly using the tenants of the ICS which would have best attack the complex unfolding situation with an ACA activated with the activation of IMTs. Hindsight bias on my part…


I have always taught and believe the following: Make ICS Work For You, Do Not make You Work For ICS.

The beauty of ICS is that it is fluid and you can make it fit your current organization, tactics, priorities, and strategy. Does this push the Pure ICS envelope, yes. Do leaders often push the envelope in all facets of any endeavor? If it works, it works. Later on can it be changed, yes. As long as your ICS organization meets your Leaders Intent, I am good with it. Adapt and overcome needs to continue to be our creed in emergency management.


I think this is on point. With incident complexity only increasing, incident size increasing, and available resources only decreasing; creativity is the only way we will be able to deal with what’s coming our way. As long as creative use of ICS is accompanied by clear communication of who what and why, it is the answer not the problem.


You have presented a lot to unpack. I have about 700+ historical FIRESCOPE documents from my days, but I am not sure I had that exact copy. I’ll have to do a deep dive but truly appreciate it.

Regardless, what you say is right on point - no surprise there. The only comment at this point will be about the “Planning Ops” position as it is called. FIRESCOPE has finally started referencing it correctly as “a Deputy Operations Section Chief may be assigned for specific tasks (e.g. planning operations, day/night operations, evacuation, or contingency planning).

However, I continue to hear people think it is an Operations Section Chief with equal authority to the “field Operations Section Chief” so there are two OSC’s in charge at the same time, a I-100 fail. I remember that after some missteps by our team in the early 2000’s we developed a “Deputy Operations Section Chief - Planning” Position Description to make sure no one got their wires crossed. Stopping a planning meeting in mid stream because of a “thumbs down” is humbling.

Now to this point, I have not recited my credentials with this post because my background is not the point of the post. Let there be no question that I am trained and qualified to perform today and without being a braggart do a damn good job. This is not a slam at IMT_Geek as I well know and respect his credentials and accomplishments and appreciate him asking me to articulate my beliefs about the bastardization of ICS.

I didn’t consider anything a slam because I was asking and had not offered any opinions, criticism, or anything I could get slammed for “yet.” I wanted context since several issues were floating.

DOCTRINE. One of the biggest and most significant issues we face today with ICS being removed from the NIIMS and NWCG/FIRESCOPE to DHS as NIMS, is the lack of doctrine to support its correct implementation. That isn’t entirely DHS’s fault as there was a lack of doctrine and agreement at several levels and between several agencies prior to its removal. The end result is exactly what you described, Field Operations Guides don’t jive and your comment "I must mention how interagency differences create serious safety and operational differences under the ICS Components, Consolidated Action Plans. That is where one agency does one thing and another agency does another tactical action." That is unfortunately true. That’s different from the “rigid flexibility” and other coined phrases to describe the ICS.

Doctrine may not get down to the clockwise level (although some say there is reason for going there), but having implementation guides and better training in implementation would prevent the backwards approach. I’ve seen many incidents where it was clockwise starting on the left flank and counterclockwise on the right flank. One side was alphabetical, the other was in reverse alphabetical order. That’s why you see a lot of IA’s with Division “A” and “Y” since it permits expansion in a logical order, been there, done that. Again, there is no doctrine that states you can’t, but a complete counter-clockwise application might be a head scratcher for most of us.

I’ll admit to being blessed to be in a unique position of opportunity to help push for change or bring best practices to the national scene. With that comes the responsibility to listen, just be quiet and use my two ears and one mouth example. That’s why I asked the question without opinion and that’s why I am listening.

The Calfire 24-hour operational period is a good example of a best practice. It needs the background to be pushed into the national scene as just that. That is being worked on.

The use of “Sectors” to further manage the span of control above the branch level is a very interesting concept. I am waiting for the Calfire IMT to write something up so that can be discussed at the national level.

There are a ton of examples where doctrine and documentation would help agencies properly apply ICS and not bastardize it. As highly experienced folks like yourself discuss these issues, I take notes. If I could help 10% of the time at least that’s one step forward.



Thank you very much for the helpful clarification and information. We are on the same page with what is happening.

I fully agree with the idea that the Planning OSC is a Deputy OSC. Glad FIRESCOPE is recognizing the usage and how they are phrasing the implementation.

It is a shame that agencies cannot better cooperate. Top level executive leadership from all agencies particularly federal and state agencies must work more closely and ensure subordinates do the same which doesn’t appear to be the case these days. We cannot allow the intermediary and working level fire line supervisors to be recalcitrant, do their own thing and snub the other agency with their indifference. I still support my thought, “It is all our responsibility to maximize our similarities and minimize our differences.”

Thank you for your commitment from your position of respect by so many to continue to solicit ideas and affect positive change. Will always be uphill and was, in fact, uphill when the originators of ICS shook the world up with change from the former Large Fire Organization (LFO). Probably many wildfire executives read this blog. I hope so and hope they understand our commitment to positive improvement which will provide the firefighters and the public the service they deserve and expect. Thank you, again.


In the past the previous fire paradigm, we would see a complex of fires maybe totaling a few thousand acres. At that point some of the larger fires might be named, but many would just be a single branch with a few divisions.
What has occurred in the last 8-10 years are fires that routinely burning into the 50,000-100,000 acre category.
These fires cross into multiple counties and CAL FIRE administrative units, and forests as well as cities. While that occurred in the past, not to the extent that it is occurring now.
Zoning even when a single IMT is present has allowed a level of command to extend down that without an individual OSC responsible for that zone, would not occur because of span of control issues.
Believe it or not… some counties that are next to each other do not get along. It is abhorrent to them to see someone located in another county talking about what is going to occur in their county…
Zoning allows the individual OSC ( Dep OpsXXXX) to work with the evac process, firefighting effort and re-population/recovery phase and to build relationships within that particular county while representing the IMT. This also occurs at the Liaison level, but it is important that a fire ground commander can have the familiarity with the dirt to speak intelligently about what is going on.
Part of that process has been driven by the politics that are occurring now at the ICP. We have a robust presence in the Liaison shop and PIO and it is still often overloaded.
The old paradigm allowed the OSC to set the strategic goals, and then work through the branches to ensure they were accomplished.
The Dep Ops( Planning Ops ) was supposed to be the in camp OSC and be the single point of contact between Resources and Ops. They would also attend the meetings during the day and answer basic Ops questions and issues as the lead OSC was out making a lap around the fire.
It is not possible to make a lap around a 50,000 acre fire, let alone a 960,000 acre one.
So, zoning became normalized and has proven its value. It has allowed a Dep Ops to be the operational lead for that zone and ensure continuity of operations is in place.
When zoned, the Dep Ops in camp becomes Dep Ops Admin.

What do you do when two IMT’s from different agencies are assigned on the same fire and the fire is zoned? And your portion of the Zone is in excess of 250,000 acres and spanning thee different counties?
On top of that there are already alphabetical divisions and numerical branches assigned? And the fire has had a few days to make 3 and 4 mile runs, so now your alphabet has gotten out of whack.
Add into the scenario a resistance by one IMT to amend the map and breakdown the zone lines into something that makes sense.
You go to groups… and branches named geographically. At that point you cannot have a zone within a zone… and you would have a single OSC running a 250,000 acre fire in multiple counties with multiple land owners and stakeholders.
Remember the cat is out of the bag… hire retired firefighters to get access to the IMT and have your issue pushed to the top by using the personal relationships … so now everyone has access to the IMT.
With that, SM has allowed everyone to have a voice and to make statements that are not accurate.
The OSC is usually caught up all day dealing with politicians showing up, FB live briefings and meetings over evacs.
There is usually a line out of the OSC trailer longer than the line to see Santa of people who want to yell at the OSC and many of them are former firefighters…
So based on all of that you zone it. And now you run into a situation where you already have two zones… so you have to find something else that works. I guess you could call it a “Zebra” but Sector seemed to work better. So the Sector becomes a subdivision of the zone and is led by a qualified OSC. From there you maintain your branches and divisions.
But what do you do where the zone lines touch and there are already branches and divisions on a map… Add into that … one agency works 24’s and the other works 12’s. One of the IMT’s has a lot of resources( comparatively) and the other does not…
You create groups that are named and branches that are named, They exist in the same geographical area as the lettered divisions and numerical branches. These groups and branches are there to maintain unity of command and accountability and to ensure that the goals of the DPA agency administrator are met.
That is just the simple facts of the new fire paradigm that we are in.


One thing the ICS was not designed nor aver able to correct or overcome; politics and/or improper implementation. It is irritating when politics screws it up but then the unknowing blame the ICS for not being a viable system. Then again, people forget that the LFO couldn’t either.

I followed along most of the discussion on Zones and Sectors. FIRESCOPE has had the zone concept dialed in for a while, and I remember being on the “Biscuit Complex, Zone 3” back in 2002.

Zone – A defined geographic area or function utilized to support the management of an Incident (i.e., Area Command). A Zone may be assigned an Incident Management Team(s) or IC to provide management of a defined area or function. Zones may be identified geographically, numerically, or by functional name. (ICS 420-1.3, Managing Large Scale Incidents – Area Command, January 2020)


A Zone is a tool that may be used in Area Command. A standardized Area Command implementation plan, and operating policies and procedures should be developed, fully integrated, understood, and exercised prior to implementation. Pre-incident planning, coordination, training, and exercises are defined as Preparedness Elements of NIMS.

Zone - A defined geographic area or function utilized to support the management of an Incident (i.e., Area Command). A Zone may be assigned an Incident Management Team(s) or IC to provide management of a defined area or function. Zones may be identified geographically, numerically, or by functional name. (FIRESCOPE FOG, 2017)

Many times I have seen zones used on incidents to break them up and place an IMT into a zone. I’d have to think when/if I have seen an IMT divide and manage multiple zones on it own within its own incident. The definition doesn’t seem to follow. Zone is used in the singular, not plural.

The use or search for an organizational construct for an IMT to assist in managing its own zone or area has been the hot topic lately. Sectors is one of those that has been introduced and actually implemented in the field. I have previously written about this in the “Cal Fire Use of Sectors” thread. As the DHS gets closer to the 5-year refresh cycle for NIMS, of which ICS is a part, I am hoping that the folks that have been asked to write up Sectors do that so I have some time to socialize the concept with the various agencies. It is something that needs to be documented so it can be discussed on the national level. Although possibly a heretical statement, I’d love to see a viable replacement for the two separate operation sections options as currently taught in I/ICS-400.

There is a fine line between an IMT field testing a concept or idea and practicing something that has gone off the rails or is a misapplication. When you add in politics, well, we have all three helping or gumming up the works right now.

Request: If you happen to see/hear/ or know of a possible best practice or new application, please PM me so we can discuss. I won’t bore the general audience with the details. But if very experienced operators see something, please say something. The only way to improve is to constantly look and assess and stay open to ideas.


Actually, I would call that an IMT failure. The failed plan is one symptom of a larger issue that transcends multiple functional areas, not just the operational aspect. But I completely understand your point and agree with your thought.

The document, “Defining Standardized Performance Capability Metrics for Incident Management Teams Based on Resource Typing Levels,” subtitled, “A System To Standardize the Performance Capabilities for Typing Incident Management Teams” is working its way through the system. It will lay out specific measurable metrics that can be used in curriculum, exercises, and evaluators to assist in determining a teams capability and performance level. What you described would show up very plainly. “Boise, we have a problem. Over…”


The Soberanes Fire in 2016 had multiple zones under one CF IMT with a fed IMT brought in to shore up overhead positions. There were multiple camps, multiple briefing areas, and long travel times. Every day the 215 information gathering was impacted by comms issues. The difference in agency policy was a hindrance at times, and the C & G meetings were sometimes spicy. It was my first incident as a qualified Type 1 PSC, and I am not ashamed to admit I was overwhelmed at the complexity of the incident. There were some lessons learned the hard way on that fire. I went through AAIM prior to this incident. AAIM is a great all hazard class, but was no match for the Soberanes…


No class or exercise can prepare you for something like that, unless it was a xx day long, sleep deprived, full-scale exercise. Heck, at that point, just go to an incident.

So, looking in the almost always perfect or better than xxx, hindsight. If you were king for a day and it happened again, what are some things you think might be worthy of trying or implementing or experimenting with? Splitting it into an Incident Complex and using two IMTs or ??

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I am a fan of sectoring. Zone, sectors, branches, divisions. If you run with the 5:1 span of control ratio, that’s up to 125 divisions. We discussed having the zone number in front of the division (Div IA, Div 2A) to maintain the 26 letters. Another option was double or triple divisions (A, AA, AAA) for the different zones. The scope of the fires these days is challenging the traditional incident organization. That’s the beauty of ICS, it’s scalable.

I think one IMT per zone, and the IMTs should have frequent communications with each other at all levels. My experience has been pretty good with info sharing between the teams. It does take effort though. We have the other team’s IAP cover (with associated QR codes to download), the 205, 220 as well as adjoining 204s for the zone breaks included in our IAP. The 204s, 205, and 220 will be watermarked with the other Zone name on them to lessen confusion. The 209 is usually negotiated at the IC or region level on who will handle, and then a daily process between the SITLs is setup. We have done joint C and G meetings, which sometimes work. A wise old FF once told me that “ego is not your amigo.” If we can check the pride and ego at the door, and do what the public is paying for and expecting us to do, we will be successful. Easier said than done…