Vacation Lane Group location:

338 Smith Point Road
P.O. Box 327
Reedville, VA 22539
Tel: (804) 453-3410


Click here to enter Fifteen Charlie - a weblog on the policy of emergency preparedness

Click here to enter Homeland Security Watch - News and analysis of critical issues in homeland security today.







The Vacation Lane Group (VLG) is a nonprofit Virginia corporation dedicated to operating in the context of a democratic society to assist in organizing and expanding knowledge of Emergency Management and Homeland Security. Since October 1, 1999, the VLG has engaged in a variety of projects and references are available on request. William R. Cumming, the President and CEO of Vacation Lane Group, a legal expert and former FEMA attorney, has extensive experience in the fields of Homeland Security and Emergency Management. Details are as follows:


1999-Present- President and Chief Executive Officer The Vacation Lane Group

1979-1999-Office of the General Counsel, Federal Emergency Management Agency (positions and duties in chronological order -from the most recent to least- are given below:)

  • 1993-99 Senior Ethics Attorney

Administered the regulations promulgated by the Office of Government Ethics as those regulations applied to appointees and employees of the agency. Responsible for the first successful audit by OGE for its ethics program since the inception of the agency.

  • 1992 Acting Associate General Counsel for General Law

Administered and litigated issues concerning FOIA, Privacy, OPM and Merit System Protection Board regulations. Responsible for legal aspects of FEMA procurement requirements. Responsible for legal support to the Goodpaster/Trefry BlueRibbon Panel on FEMA’s Practices. Acted as FEMA’s first Alternate Dispute Resolution Official. Organized the first systematic administration of Tort claims filed against FEMA, and assisted in successful resolution of many of those claims.

  • 1990-91 Assistant General Counsel for Program Law-Projects

Responsible for development, implementation, and legal review of all programs involving the response to unexpected national security emergency events, and the response to all technological hazards. Developed and operated the first OGC system of legal precedents. Provided technical legal guidance for inter-directorate issues arising within FEMA. Responsible for conduct of sensitive negotiations, including Executive Order review and drafting concerning FEMA’s authorities.

Responsible for determining the application to FEMA of statutory changes when FEMA was not specifically mentioned in the statute, for example hazardous materials legislation.

  • 1989 Acting Associate General Counsel for Program Law

Responsible for legal administration of all statutes authorizing FEMA to conduct programs, functions, and activities.

  • 1986-88 Assistant General Counsel for Program Law- Projects

Responsible for development of legal positions of FEMA related to planning, preparedness, response and mitigation for both peacetime and wartime civil emergencies and integration into existing National Security institutions. This included the following:

  • Conceive and help implement legal policies and procedures related to warning and notification systems, communication systems, population relocation, protection, and damage assessment during unexpected events;
  • Coordinate and provide legal assistance to assure continuity of the federal government in a wide range of unexpected events;
  • Assist in provision of legal support for the protection of industry, post-attack recovery and economic stabilization during national emergencies;
  • Develop legal authorities and provide assistance for the emergency evacuation, and/or sheltering of the population;
  • Lead counsel for FEMA from 1986-1990 for administrative litigation involving the license application before the NRC for the Shoreham Nuclear Power Station;
  • Responsible for legal aspects of FEMA’s implementation of national telecommunication policies including administration of the AT&T consent order;
  • Provide technical legal assistance to State and local government attorneys on emergency preparedness and response;
  • Develop legal systems to prevent fraud, waste, and abuse in FEMA’s programs, functions and activities.
  • 1979-86 Associate General Counsel for Litigation
    • Supervised all attorneys and paralegals performing litigation services in cooperation with the Department of Justice for the Director and General Counsel of FEMA;
    • Established and coordinated Regional Counsels;
    • Determined trial and appellate strategy and appeal recommendations for FEMA and coordinated for the Department of Justice when FEMA cases had government-wide impact;
    • Provided legal advice to the Federal Insurance Administration (FEMA) including responsibility for preparation and signoff of legal opinions, regulations, and conduct of litigation.

1974-1978 Office of the General Counsel- DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

Supervisory Trial Attorney

Supervised seven attorneys; prepared all appropriate pleadings, motions, and appellate briefs in cases related to HUD programs in federal trial and appellate courts. Principal legal advisor to the Federal Insurance Administration (HUD) and Federal Disaster Assistance Administration (FDAA). Also reviewed, drafted and commented on legislation.


Tax law Specialist and Legal Advisor in various sections of IRS including the Assistant Commissioner (Technical), Assistant Commissioner (Stabilization) and Office of Chief Counsel. Details to provide legal support to IRS Intelligence, Treasury Office of Tax Policy, Customs and Alcohol, Tobacco, and Firearms.

On the immediate staff of Assistant Commissioner (Stabilization) Edward Preston as a liaison on enforcement matters to the Cost of Living Council (Rumsfeld), Price Commission, Pay Board, and other entities.


 Juris Doctor, 1967-University of Virginia, Charlottesville, VA

Bachelor of Arts, History and International Relations, 1964

Magna cum Laude Lehigh University, Bethlehem, PA

Artillery Officer Candidate School, Ft. Sill, OK-January-July 1968



Commissioned 2LT, Field Artillery, July, 1968

United States Army, 1967-1970; 1LT Field Artillery Highest Rank

Nuclear Weapons Unit Commander 1968-69

Battalion S2/S3 1969-1970

Overseas Service, Federal Republic of Germany

Decorations: NSDM, Army Commendation Medal



Admitted to Virginia State Bar (Inactive as of December 1999)

Admitted to Supreme Court of Virginia (Inactive)

Admitted to United States Tax Court (Inactive)



  • William R. Cumming and Richard T. Sylves, "FEMAs Place in Policy, Law, and management: A Hazardous Materials perspective 1979-2003, in Homeland Security Law and Policy, William C Nicholson ed. Springfield, Illinois: Charles C. Thomas Publishers, 2005. (pp. 23-55)
  • Author of individual articles in various newsletters including:
    • The American Civil Defense Association’s The Journal of Civil Defense
    • American Strategic Defense Association’s ASDA Newsletter
    • Best Practices In Emergency Services

    Co-Author “FEMA’s Path to Homeland Security:1979-2003”, Journal of Homeland Security and Emergency Management: Vol 1: No. 2, Article 11

    • Co-author, Homeland Security Time Line: An Historical Overview of Organizations (1933)-2003), (special publication depicting the basis and the history of Homeland Security Organizations in the U.S.), Version 1.0 2003
    • Co-Author-The Terrorism Time Line TTL: Selected Milestone Events and their U.S. Outcomes 1988-2001)
    • Co-Author-Working Paper NSF Grant #CMS-02316-24, Major Terrorism Events and their U.S. Outcomes (1988-2001) Also published as Working paper #107 University of Colorado Online Publications, 2003
  • Contributor-National Security Law, Cases and Materials, 1 st, 2 nd, and 3 rd editions, Dycus and Raven-Hansen et al. ( Aspen, 2002, Third Edition)
  • Contributor-Emergency Response and Emergency Management Law, Cases and Materials, 1 st edition, William C. Nicholson (Charles C. Thomas, July 2003)




  • National Defense University- Industrial College of the Armed Forces
  • George Washington University
  • National Emergency Training Center


Last revised:September 30, 2005


Home | Services | Experience | Analysis | Standards | |

Website designed by Irmak Renda-Tanali

Copyright © 2005 Vacation Lane Group