FEMA Comment Period Open Until Dec. 2 on NIMS Changes

November 28, 2013
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Thanks to EAS Subject Expert Gary Timm, I found out that FEMA is accepting online Comments prior to their National Advisor Committee (NAC) meeting on December 3. Their NAC will be discussing the National Incident Management System (NIMS) at this meeting. Followers of this list know that some of the major unresolved issues with emergency public warnings are the lack of a comprehensive, unified overall United States public warning strategy, and that many in the emergency management community have not yet taken to heart the reality that emergency public information is a core emergency response resource. Below is the preface for comments posted to the government’s online Comment filing system, Regulations.gov. [ http://www.regulations.gov/#!documentDetail;D=FEMA-2007-0008-0040 ] I was not aware until yesterday that our government had a way to comment on non-FCC issues.

The article I submitted can be viewed on this site at: { http://eas.radiolists.net/the-2013-national-emergency-management-association-nema-forum/ ]

I encourage all on this list to submit their own comments on the advisability of having NIMS policies and training expanded to reinforce emergency public warnings as a core response resource, or at least support the comment I filed on behalf of the BWWG.

Richard Rudman

BWWG Core Member

The article makes the case that Emergency Public Information (EPI) needs to be actively and carefully managed by the emergency management community as a core response resource. Other exiting core response resources are damage assessment teams, search and rescue teams, emergency supplies, and all other elements that come under the management span of control of the response community.

Doing what this article calls for requires that new NIMS training modules must be written leading to significant changes in how emergency public warnings are managed. The author bases the need for this change on his work in 2002-2003 as one of the 17 founding trustees for the Partnership for Public Warning (PPW) that wrote seminal reports that let to FEMA’s adoption of the Common Alerting Protocol (CAP) as the core of its Integrated Public Alert and Warning System (IPAWS). One of the PPW’s major findings expressed in its reports what the glaring lack of a national warning strategy for the United States. To date, this overall U.S. strategy for warnings does not exist.

Some will say that this issue is already covered in NIMS. Not so to the degree necessary. During the critical early hours of the response phase of emergencies when having the public do or not do certain things can help manage the event to a better and earlier outcome is not clearly covered in NIMS training. Those “certain things” can and should be communicated timely and clearly under the heading of EPI, and must be part of the initial planning process for overall response for declared emergencies.

The writer is current serving on the Federal Communications Commission’s current Communications Security, Reliability and Interoperability Council IV (CSRIC) Working Group 3. He is also the Vice Chair of California’s Emergency Alert System State Emergency Communications Committee (SECC).