I have a similar adage when describing ICS as: Although ICS is a standardized approach to managing incidents, it is flexible in its ability to meet the needs of the incident, not flexible to meet the needs of the “agency”. When we see ICS adapting to the agency or individual, then we start seeing the “bastardization” of ICS occur.
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Groups are an efficient method of tasking specialized or limited resources. Heavy equipment group, structure protection group, investigations group… Groups are an effective and necessary division of labour within operations that are not “bound” to “divisional boundaries”. Can a functional branch be assigned to an entire incident? Yes. Can a group be assigned to a Functional or Divisional Branch ? Yes. Can a group be assigned to a Division? Not in alignment with ICS doctrine. Tasking resources to Divisional only assignments gives me the shivers of the LFO days.
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The problem with “doctrine” and academics is that they take place in a sterile atmosphere, without the injects of politics, human factors and staffing constraints.
So, can groups function within divisions the answer is yes.
ICS was built for us… the truth is the public could care less about how we do what we do, they just want it done.
Go back to Task Purpose End State…
The goal is to mitigate the incident. So, to do that as an OSC if I need to call it the “Pie Group” to get the job done… then so be it. I am over watching communities burn and resources being lost.
The current ICS system was built in a time when we were not dealing with the incidents we are now.
How do you deal with a search and recovery operation for potentially hundreds of people within a fire footprint where there is still firefighting operations going on? You create branches and groups that over lay the incident and ensure that the naming convention is different but there are shared communication channels.
This is all handled at the briefing.
How do you deal with two IMT’s working in the same area where there is a zone break. There is a significant threat to infrastructure, communities and resources. One of the teams does not have the resources to complete the mission, the other does.
One of the IMT’s does not have a good track record protecting these assets, the other does.
There is political pressure applied to not allow any other communities burn…
So you create groups and branches and they work within the existing footprint and accomplish the mission.
No black ops…
It is about cats and dogs. Cats will crap behind the sofa, a dog will crap right out in the middle of the living room and go back to playing.
I am a dog guy.
Read “Team of Teams” or “Not a good Day to Die” if you want to see the results of clinging to doctrine when the doctrine has not evolved to deal with what is really happening.
If I am a part of bastardizing ICS, then so be it. My conscience is clear because I achieved the end state that was given to me by the agency administrator and my IC.
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I guess I should provide my feedback since it looks like I’ve presented a sort of Pandora’s Box related to the us of the ICS. 
I feel that the Incident Command System is a “fluidly-rigid” structure. It should be used, like CaptMack said, to work for you, and not you work for ICS. Some portions of the ICS may not be needed to be successful (this is more relatable on smaller incidents), while large or complex incidents will need all facets of the ICS to be implemented. I think that “bastardization” comes into play when you have this recognized and accepted “playbook” (ICS) that is routinely used every year with great success, and someone feels a need to change how a portion of it is used without vetting it. While I can understand that “if it works, then it works” can and should be encouraged, but it also needs to be understood that that train of thought also opens the door to a normalization of deviance if there is no type of AAR or evaluation done. Case in point, a task force identifying themselves as a structure protection group rolls into a division and says they’re there to provide structure protection and structure firefighting to this specific neighborhood. They are not on the IAP (there is no structure protection group), they are operating on their own tactical channel that is not even assigned to the incident, and they are not communicating with the other resources on the division who have been assigned to structure protection through their DIVS. They aren’t even communicating with the DIVS throughout the potion of the operational period that they’re there. Now, I know this has a lot of red flags for a lot of folks reading this because it raised a lot of concerns for me because the type three strike team I was the STEN of on this recent fire was working in conjunction with the other resources on the division that had a plan developed and was implemented when this all came down. Did this strategy and tactic seem to “work” for that Task Force? Probably for them, but not for everyone else including the DIVS. So now everyone on that Task Force has a mental reference to pull from as being '“successful” so they’re more apt to do it again in the future. Normalization of Deviance. As a side note, we did tell their TFLD on multiple occasions that they need to get on our Tac Channel and let DIVS know what they’re doing. I don’t know if they were talked to after the operational period by the DIVS or not.
To the point of functional groups, it is more specific to them “roving”. Sometimes they can be successful. However, there needs to be a clearly communicated plan of their intent and use. This goes to a point that I think both Bogusthunder and FireHawkC3100 made is that they need to work within the IAP and also ensure communications are maintained with adjoining resources. A firing group that develops a large firing plan that would span multiple divisions should communicate their plan correctly, how it would be implemented, what support they would need from the divisional resources, etc. Unfortunately I have heard of, and worked in DIVS where that wasn’t communicated and low and behold, here comes a firing operation where we now have to change our plan of operations to support that. Wasn’t a huge deal, but it was enough to cause a bit of confusion. In my experience, functional groups traversing multiple divisions has rarely worked out well as the groups tend to take on an almost rogue mindset.
Like I said in my original post, I subscribe more to the thought of giving the DIVS the resources that they need to accomplish the management and control objectives assigned to them by Ops. This is due in part to an evolution of tactics and resource use over time. There used to be a time where Type 1 engines were only thought of as structure protection resources and that was it. Over time that has changed. I’ve was on a type one strike team 15 years ago when we were tooled up and put in crew buggies and cut line for our 24 op period. An evolution on the use of resources. Do groups serve a purpose? Sure, it gives the system flexibility. But in my opinion, a DIVS has responsibility for everything that needs to get done within their piece of land for however long that will take. Having a functional group working within a division for an operational period seems odd. Why wouldn’t those resources be assigned to the DIVS? I guess my train of thought might be somewhat biased on my fire service upbringing in CA.
With regards to the Divisions and branches being laid out counter-clockwise on the map. It could have been an accident, or it could have been done on purpose. I don’t know so that’s why I asked the question. I want to know more. If done on purpose, I think that’s a problem that should be rectified as quickly as possible to fall in line with common practices. If it was an accident, it should be acknowledged, updated, communicated, and move on.
One last point, ICS will, and should, always be evolving over time. As many of you have stated in this and other posts, wildland fire growth is nothing like it was even 10 years ago. The use of Branches and Zones has become more prevalent and established sooner on in the incident. Sectors have made their way in a time or few. Unfortunately due to the recent large losses of lives and property, evacuations are being called earlier in an incident it seems like. Much to CaptMack’s point, adapting and overcoming should be at the forefront of emergency management. I would add that validation of those adaptions needs to occur through critical evaluations. ICS has been adopted/modified up to the national level from something that was created in CA roughly 50 years ago. It’s been used for more than wildland firefighting with success. It may not look the same for a hurricane, or when used for 9/11, but it was adapted to work for the complex incidents to bring span of control, unity of command, clear objectives, and many other things. If anyone is interested, I would encourage you to listen to a podcast called MCTI Teamcast. Look for episode #21, The story of Wildland Fire and 9/11. Very interesting history lesson on how a predominately Wildland IMT was brought in to assist the FDNY in managing the search, rescue, and recovery missions of 9/11.
I’m sure my post is all over the place, and I apologize if it reads that way. I appreciate all of the information presented thus far and admittedly have learned a few things from those of you who do, or have, participated in a higher level of the ICS than I have. I always enjoy gaining knowledge from the more knowledgeable. I could be wrong/misinformed on a lot of my viewpoints, it just my perspective from my experience in the CA Fire Service at both the state level as well as a majority at the local government level.
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Great topic been waiting for the time to jump in, as was said in the previous post ICS is and needs to be flexible. Division do need to be give the resource to accomplice there objectives but the last few years that has gone out the window. With so many fire and lack of resources we are forced to do what we can with what we have. With that being said on the last fire I was night Ops with limited resources and a running fire, as was said earlier communication is key to ever operations. We would adjust every night with a new plan for that operation because things changed during the day. My Division for the first couple of nights put a plan together to anchor and flank, when we add another division and overhead support a plan was developed between all involved. This fire was in Unified Command and the cooperation between all folks from the top to to the bottom made this successful. Folks if this is the new norm then we need to adapt to the current situation. Remember we are here to mitigate the situation and sometimes that means its not pure ICS.
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Though the comment wasn’t directed to me by name, the response to my “no doctrine” comment seems like it might have been. I’d like to better explain what I meant. I’ll be more explanatory than usual in case there are folks who may not be super well versed in the application of the ICS. If you are very well versed, please don’t take offense, it is not intended that way - I just need a little grace with verbosity.
The problem with “doctrine” and academics is that they take place in a sterile atmosphere, without the injects of politics, human factors and staffing constraints.
I will wholeheartedly agree that poorly written or out of date doctrine is inexcusable and restrictive. Properly developed doctrine takes those complexities mentioned into account and provides the latitude for organizational adaptability or initiative to meet the situation. Properly developed doctrine provides the guard rails to keep someone from going off the rails and using ICS in counterproductive ways that cause fireground confusion. It should not be written to prevent the adaptability, agility, or initiative needed to get the job done, hence why it is referred to as “rigidly flexible.” However, doctrine does help prevent rogue or deviant application or organizational confusion that can increase the fog of war or introduce dangerous conditions.
So, can groups function within divisions the answer is yes.
ICS was built for us… the truth is the public could care less about how we do what we do, they just want it done.
Completely agree. Those have been established facts for decades.
Go back to Task Purpose End State…
The goal is to mitigate the incident. So, to do that as an OSC if I need to call it the “Pie Group” to get the job done… then so be it. I am over watching communities burn and resources being lost.
I don’t believe there is doctrine that prevents anyone from naming a group the “Pie Group.” A group is organized around a functional purpose. The implementation guides (like the FIRESCOPE FOG) and curriculum state they should be named after the function they are organized to perform. Naming them after the functional purpose or desired end state simplifies understanding the organizational structure and promotes a more focused, less confused, and safer operation. It is a lot easier to understand the task, purpose, end state of a group that is named the “Evacuation” group than one named “biscuit.” Again, that isn’t in doctrine, but in the implementation guides that I also mentioned in my original comment. The NIMS ICS does not have any implementation guidance developed. Everything is in curriculum, some that hasn’t changed in decades. That was my original complaint. We need to be adaptable, intuitive, and forward leaning. That’s one of the reasons why I would love to replace some outdated doctrine (two operations sections - a hold over from the 70’s) with something that sounds like it may be a good replacement (Sectors between the OSC and the OPBD) to mitigate the span of control issues we are seeing every single incident. A four page 204 works – until it doesn’t, and OSHA gets involved, and the span of control is deemed completely out of control and against industry practice, and then there are lawsuits, AARs, and everything we loath to read about.
The current ICS system was built in a time when we were not dealing with the incidents we are now.
I completely agree. That is why I stated that doctrine needs to be properly developed and it needs to be kept up to date. Again, properly developed doctrine that actually enables organizational adaptability while preventing rogue warriors from causing confusion. Right now, we have pretty much no doctrine, except in California, and that isn’t nationally accepted yet.
How do you deal with a search and recovery operation for potentially hundreds of people within a fire footprint where there is still firefighting operations going on? You create branches and groups that over lay the incident and ensure that the naming convention is different but there are shared communication channels. This is all handled at the briefing.
I may not understand what “over lay the incident” is intended to mean, if so, my interpretation may be wrong. If so, I apologize. If you mean the OSC is faced with a large aircraft accident into a building and honoring the priority of Life Safety they have the objective of LAST, Locate Assess, Stabilize, and Transport injured to an appropriate facility. To do that the OSC creates a functional branch(es) to perform “search and rescue” (or any other functional name that works) and that those functional branches have several groups under them for span of control or functional diversity. If that’s what we are doing, then that’s great. If you have organizational branches and divisions (and maybe even groups too) that are working on the firefighting objective, that’s great. That is completely supported by the existing doctrine and implementation guides and a good use of ICS. The FIRESCOPE FOG “Multi-Casualty – Multi-Branch Response Organization” speaks to almost your exact thoughts.
How do you deal with two IMT’s working in the same area where there is a zone break. There is a significant threat to infrastructure, communities and resources. One of the teams does not have the resources to complete the mission, the other does.
One of the IMT’s does not have a good track record protecting these assets, the other does.
There is political pressure applied to not allow any other communities burn…
So you create groups and branches and they work within the existing footprint and accomplish the mission. No black ops…
Wow, nothing like a complicated incident. Sounds like a good AAIMS or 520 scenario. I’ll look past all the red flags that might be possible and try and focus on what (I hope) you mean. If the zone break is separating the 2 IMTs area of responsibility and where they meet the IC/OSC/OPBDs agree that one of the IMTs branches can assist the other IMT in completing a mission by operating in the other IMTs area? Okay. It might not make some people happy (finance folks or attorneys) but they aren’t out in the field. There might be some agency policy involved - if word got out, if different jurisdictions or AAs are involved that may raise a stink somewhere - if word got out. But that is why you need organizational adaptability, trust, empowerment, collaboration, over-communication between involved elements, and no safety gear assigned to finance folks and attorneys. I know of no ICS doctrine preventing it, and I would never ever want doctrine to go there, that is cumbersome, restrictive, dogmatic, and the antithesis of good leadership traits. So, if I was the OSC, what happens at the Zone Break, Stays at the Zone Break, mission accomplished, desired end state accomplished, met the Commander’s intent.
The statute of limitations has passed so I can admit to examples like our IMT letting the Firing Group continue on into the other zone (managed by the AK IMT) - at their specific request, and after briefings and over communication occurred.
Read “Team of Teams” or “Not a good Day to Die” if you want to see the results of clinging to doctrine when the doctrine has not evolved to deal with what is really happening.
My original complaint was quite plain in the fact that what little national doctrine there is, is out of date and has not evolved to keep pace with current incidents. Most of the doctrine is actually recorded only in curriculum and that is not an appropriate system. So, it is essentially clinging on like you disagree with. We might be in complete violent agreement on that. Properly couched, current, and flexible doctrine supported by good implementation guides that provide organizational flexibility, adaptability, and personal initiative are what helps focus the organization on the mission without strangling itself.
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I am not sure anything you described is not “pure ICS.” If that is what had to happen I don’t think anyone is going to throw rocks, there is nothing wrong with reconstituting your operation in the face of failure. Pure ICS means that you can’t have a Functional Group subordinate to a Division as that will cause all sorts of confusion. Pure ICS does not mean you can’t modify your plan on the fly and deconstruct divisions and reconstitute as groups or different divisions. Show me anywhere that “pure ICS” takes away the OSCs latitude from them so they can’t manage their operational resources. The biggest issues with an OSC having to pickle the tactical plan they just launched is not communicating what’s going on to the other C&GS that need to support what they are doing. Even inmates won’t work if you don’t feed them, so you better be communicating with your LSC. The SOF has their “stop” card, so you better clue them in to your revised plan, etc. Outside of the team dynamics of what happens if the OSC doesn’t communicate, the ICS police are not going to show up and handcuff anyone. I admire your adaptability and initiative in organizational modification to meet the strategy.
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To the point of functional groups, it is more specific to them “roving”. Sometimes they can be successful. However, there needs to be a clearly communicated plan of their intent and use. This goes to a point that I think both Bogusthunder and FireHawkC3100 made is that they need to work within the IAP and also ensure communications are maintained with adjoining resources. A firing group that develops a large firing plan that would span multiple divisions should communicate their plan correctly, how it would be implemented, what support they would need from the divisional resources, etc. Unfortunately I have heard of, and worked in DIVS where that wasn’t communicated and low and behold, here comes a firing operation where we now have to change our plan of operations to support that.
What you described is not what I call a “pure ICS” issue. It is a leadership issue. Folks who are leading Divisions or Groups are not executing all of their responsibilities “Coordinate Activities with adjacent Division or Groups” and "implementation of the assigned portion of the Incident Action Plan." are huge items to miss. If you aren’t doing that then you are a rogue warrior and a threat to the stability of the organization if you put fire on the ground and its a surprise to anyone else it may affect.
What @Ehoss84 just mentioned I forgot to, and he has an excellent point. Though it isn’t really written anywhere other than in the curriculum, Group Supervisors should CHECK-IN and CHECK-OUT with the Division Supervisor’s area they are operating in. You have a special purpose, function, or special equipment, but you are actually operating or visiting on someone else’s land/sea (the DIVS who has the responsibility), so be nice, be a leader, and do the right thing. We train READS, SOFs, FOBS and other positions to do it, so be an example and do it yourself too. No one should be surprised by anyone operating in their area of responsibility. If the $#!t hits the fan the DIVS is responsible for getting everyone out of harms way. This shows up on accident reports, you can’t be accountable for someone who is sneaking around on your land - okay, not really sneaking but not letting you know.
But in my opinion, a DIVS has responsibility for everything that needs to get done within their piece of land for however long that will take. Having a functional group working within a division for an operational period seems odd. Why wouldn’t those resources be assigned to the DIVS? I guess my train of thought might be somewhat biased on my fire service upbringing in CA.
someone else had a great example of why a Group might be a better option at times.
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.
A Division supervisor can’t be two places at once and has to remain focused on the task, purpose, end state. Trying to resolve logistical and coordination issues with utility companies and others while mopping up around multiple structures at the same time as trying to supervise, resolve logistical issues, coordinate with adjacent perimeter divisions, there is only so much that one can or should do. If you look at what is happening on incidents right now, today, download the IAPs. No one will say a word - but look at the 204’s. They are out of control. We need more first level supervision, not more resources assigned to one division. Seeing a 204 that is 4 pages long and doesn’t have a bunch of unassigned STEN, STCR, or TFLs to try and mitigate that, well, that is not pure ICS. Span of Control does not exist. That’s okay until its not okay because of an accident, then…
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“How do you deal with two IMT’s working in the same area where there is a zone break. There is a significant threat to infrastructure, communities and resources. One of the teams does not have the resources to complete the mission, the other does.”
We had to deal with this DAILY on the Dixie. It came down to COMMUNICATION and Relationship building. On the communication side, the Branch Director and the 3 Grp supervisors checked in/out of the respective ZONES at the beginning and ending of each operational period. We made a point to make contact(some times F2F with the “Night supervision” from the other zone) I can personally attest to this to the point my East Zone Counterpart said “This is the largest, multi Zone/Branch/Division/Group I’ve ever been a part of and it’s working like a well oiled machine”. The key to success in my opinion was 2 fold
- Pure ICS. No rank, qualifications mattered
- NO EGOS.
We would meet in the AM and divey up Equip/HEQB’s and merge each other’s plans to meet mutual objectives.
Finally, RESPECT. It all starts there. I tell my FF WE MUST RESPECT our cooperators even if we don’t agree with their tactics. Each agency has SOP’s/SOG’s and THEY DON’T MIX. Land Management can and does come into direct conflict at time with preserving life and protecting property.
In closing, I am required to deal with 3 different agencies SOP’S/SOG’s because of FRA/LRA/SRA overlays. WE(company officers) work together and help each out on the floor. The FRA/SRA CO’S have the added responsibility of
“Aircraft & finance” We have agreed to leave the politics to the WAGON WHEELS & STARS.
But it all starts with RESPECT. I have my FF read the other agency Mission Statements to begin the education and training. The single biggest problem with ICS has NOTHING to do with ICS in my opinion. Rather, it has to due with SPAN OF CONTROL and that is a direct result of Increased Call Volume, Longer Fire Seasons, Retirements(brain drain) and CULTURAL CHANGES that directly affect a decreasing work force.
BTW
THIS IS A GREAT DISCUSSION
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I have a question that I thought I’d bring to the subject experts although it is not exactly in line with the previous posts. I was on a fed fire recently and in the division I was working there were a lot of resources, 2.5 pages worth. There was a DIVS assigned and present. There were also multiple single resource TFLD brought into the fire. The TLFD in our area, who did a great job, seemed to be acting as a DIVS with assignments, accountability, and such. We were in a specific geographical area but with several different objectives. The TLFD we were ‘working’ for had a Type 3 ST, 2 Shot crews, 1 interagency hand crew, a dozer, FALM, and 2 WT. My question is can a task force be comprised of said resources since each has 1 leader thus making the span of control acceptable or would this be an odd duck? The TFLD then reported to the DIVS and we reported to the TFLD. I could not get an answer on the incident and am curious. I’m not knocking it by any means, it worked really well and the missions were accomplished but just curious as I’ve never been involved in that scenario before.
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WTS110, were you assigned working for a federal Type 2 IMT? If so, federal policy usually but not always does not allow Type 2 teams to branch an incident which could contribute to what appears to be a busy division or vertical organization congestion. Sounds like everyone worked, though, and the DIVS did a successful job leading the fire warriors.
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@WTS110, that is a common and acceptable method to reduce the span of control to a more acceptable level. One of the Duties and Responsibilities of the Operations Section Chief is,
- Assemble and disassemble Strike Teams and Task Forces assigned to Operations Section.
So the OSC or if there is a Branch involved, the OPBD (with concurrence of the OSC), can create T/Fs or S/Ts using the guidelines for their use. A T/F can be any assemblage of resources as long as they have common communications and a leader. So what you described is acceptable. The Strike Team Leader/Task Force Leader,
“Reports to a Division Supervisor or Group Supervisor and is responsible for performing tactical assignments assigned to the Strike Team or Task Force. The Leader reports work progress and status of resources, maintains work records on assigned personnel, and relays other important information to their supervisor.”
You stated that the TFLD “seemed to be acting as a DIVS with assignments, accountability, and such” but what they were doing was executing their TFLD responsibilities. Accountability is not mentioned because it is a common responsibility of all supervisors. The more commonly accepted responsibilities are:
- Review Common Responsibilities.
- Review assignments with subordinates and assign tasks.
- Monitor work progress and make changes when necessary.
- Coordinate activities with adjacent strike teams, task forces and single resources.
- Travel to and from active assignment area with assigned resources.
- Retain control of assigned resources while in available or out-of-service status.
- Submit situation and resource status information to Division/Group Supervisor.
- Maintain Activity Log (ICS Form 214).
I am not sure why you were not given an answer. Forming TF and ST’s or breaking them up are permitted and acceptable. Ordering and assigning single resource (often called unassigned) overhead positions to address the span of control (or span out of control) issues is one of the methods. In the older days there was a sub-unit of a division called a segment, but it was unappreciated and removed from the FIRESCOPE FOG that the quotes above come from.
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@FireHawkC3100, they have/are moving away from that guideline as it never worked and you would find branches being used on Type 2 incidents. Because NWCG is in the process of deconstructing their Type 1 and Type 2 IMTs and replacing them with Complex Incident Management Teams (not to be confused with Incident Complexes) and called CIMTs (not to be confused with CIIMTs), that will no longer be around at all.
As a side note, the new FEMA National Incident Management System Incident Complexity Guide published in 2021 permits the use of branches at Complexity Level Type 3.
Branch Director position(s) may be filled for organizational purposes and occasionally for span of control
This is an important point because it is very common for All-Hazards Type 3 incidents to implement Branches, i.e. Law Enforcement Branch, Hazardous Materials Branch, Fire Suppression Branch.
Also, the document, "Defining Standardized Performance Capability Metrics for Incident Management Teams Based on Resource Typing Levels (A System To Standardize the Performance Capabilities for Typing Incident Management Teams), describes the minimum performance capabilities of Incident Management Teams that will be implemented over time.
The minimum performance capabilities of Type 3 Incident Management Teams is:
#4, Incident/Event Operational Management (Refer to details)
- Capable of managing up to three functional branches in the Operations Section
- Capable of managing the implementation of Branch Tactical Planning in one branch
The minimum performance capabilities of Type 2 Incident Management Teams is:
#4, Incident/Event Operational Management (Refer to details)
- Capable of managing up to five functional and/or geographic branches in the Operations Section
- Capable of managing the implementation of Branch Tactical Planning in all branches
So, lots of standardization and guidance being established to smooth out some of the agency interpretations of complexity, capability, and ICS application.
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This occurred on KNP and a CAIIMT had recently taken the fire. Im certainly not pointing fingers or think it was bad. I was on type 3 ST. I asked my STEN, my BC, and we just weren’t sure of answer as neither of us were familiar with this particular situation. I was impressed with how well it worked and our TFLD who was USFS was top notch. I appreciate the feedback and education. I’ll bring this back to the station and share with my BC/STEN.
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@WTS110, it is one of the few methods available to relieve the span of control issues at the DIVS level. When a team is en-route to a new assignment it is one of the items they could look for by viewing the current IAP, if they had one, and what the current span of control looked like. Then they could add in unassigned TF and ST overhead to the pre-order or punch list. It’s a good method, as long as there are those overhead positions available. Everything seems to be getting more difficult to obtain these days.
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On the State side, the “concept” of TFLD is beginning to gain traction but still isn’t widely accepted yet. I know I was in several planning meeting this year where a Division or Group was drastically understaffed for the resources assigned or ordered. Each time there were large orders of Hired Equipment and the span of control for the HEQB’S was 8+ to 1 and in several cases 10-12:1. Each time, I suggested the use of TFLD as a solution as we regain span of control and had the ability to create sub groups for specific functions.
Finally, on the CF side S330 is being taught as AH-330 and including the TFLD concepts and training.
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