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www.PartnershipForPublicWarning.org
December 24, 2003
HOMELAND SECURITY ADVISORY SYSTEM
Summary of Public Comments
On November 6, 2003 the Partnership for Public Warning released a request for public comments
on the operation and effectiveness of the Homeland Security Advisory System. Comments were due back
to PPW by November 28, 2003. Provided below is a summary of the comments received.
Comment 1
That is one of the most common comments. Main question I hear is now that we have a color change
what do we do now. What do the colors mean? State of Hawaii has adopted the same code except it
states code black when an event has occurred
Mike Fagel
Sugar Grove Emergency Management
Illinois
Comment 2
1. It is unclear if this system applies only to “Terrorist” attack. If the United States were faced with
an overt imminent threat from a foreign nation-state, what system would we use to heighten
readiness and awareness? The HSAS as written, implies that it is only to be used as a “terrorism”
threat advisory system.
Recommendation: To lessen confusion at all levels of government by establishing a “one-
system-fits-all”, remove the terminology and implied intent that the system applies only to
terrorism. Make it a system that can be used for any outside attack threat on the U.S., whether
covert or overt. Adapt the system to be based on any potential threat of hostilities directed at the
United States; its citizens or facilities.
2. Presidential Directive #3, establishing the HSAS is vague and ambiguous. No obvious
implementing instructions are included.
Recommendation: Realizing the HSAS is new, with ongoing review and pending revision, a set
of comprehensive standardized instructions on how the system should be implemented at all
levels of Government, should be drafted once final revision at the national level completed.
3. It is unclear how, or even “if” the HSAS will supplement, incorporate, or be subordinate to the
current FBI 4-tiered Threat Level System. The HSAS Presidential Directive does not address this
issue. We continue to receive Law Enforcement Teletype messages addressing current national
threats, with the FBI threat level system assigned.
7515 Colshire Drive M/S N655
McLean, VA 22102
TEL: (703) 883-2745
FAX: (703) 883-3689
Recommendation:
a. Reconcile or modify the HSAS to incorporate the elements of FBI 4-tiered system.
b. If that is not possible, have the FBI either discontinue issuing advisories using their system, or
discontinue the FBI system entirely.
c. If the FBI continues to use and issue threat level bulletins using their own system, then it is
recommended that a “cross-walk” be published showing where the FBI threat rankings fit within
the HSAS system.
d. Ideally, the FBI should drop their system and the federal government adopt the HSAS as the
standard for government at all levels. The military Force Protection Condition (FPCON)
system is used by all branches of the military and allows flexibility at all levels of Command.
The same should apply with the HSAS. A single, standardized system adopted at all levels
will lessen confusion.
4. The current version of the United States Government Interagency Terrorism Concept of
Operations Plan (CONPLAN), dated 01/01, in Section III, Paragraph C., establishes the use of the
FBI – 4 Tiered threat level system as the de-facto national alert level system.
Recommendation: Revise the CONPLAN to incorporate the HSAS threat advisory system.
5. There currently is no formatted, standardized, secure system for distribution of HSAS messages.
Threat information is received over various mediums, including, email, law enforcement
Teletype, web sites, telephone, and the media.
Recommendation:
a. The National Office of Homeland Security should NEVER release a HSAS message to the
media before it is passed to the Governors and Homeland Security Director’s of each state.
This is particularly true if the threatened area is in our region or state.
b. Standardize HSAS message formatting at all levels. Use a formatting system similar to
NOAA Weather Wire messages.
c. In all HSAS threat messages, list a 24-hour Point-of-Contact at the National Office
Homeland Security; include callback phone numbers, fax, email address.
d. All HSAS threat advisories should be passed over the National Warning System (NAWAS),
to all states. This insures receipt of the advisory. The primary purpose for NAWAS has
always been attack warning based.
e. Institute a nationwide secure, web-based threat distribution system to allow for secure
transmission of HSAS advisories. Design this system to allow for two-way distribution of
threat information and coordination instructions. A web-based system very similar to the
Federal Information Coordination Reporting System (ICRS) that was developed for the Y2K
event would be ideal.
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6. The HSAS Presidential Directive does not address or allow for state’s to pass local threat
information up to the federal level. It appears to be a “top-down” system.
Recommendation:
a. Include in the final standardized HSAS system and it’s implementing instructions, the ability
for state’s to pass up potential threat information, which may have a bearing on the need for a
specific region to be at a lower or higher threat level.
b. Allow the governor’s of each state the latitude to set their own levels as they see fit, based on
the most current intelligence information.
c. Give local jurisdictions the latitude to also assign threat levels according to state and local
potential for an event. As an example, if Spokane County is assigned a level of “HIGH”, it
stands to reason that distant counties, hundreds of miles away in the same state, may not need
to be at the same level as Spokane County.
7. Presidential Directive #3 states, “Assigned threat conditions shall be reviewed at regular
intervals to determine whether adjustments are warranted.” What are the regular intervals? The
National Office of Homeland Security has stated that the Nation is currently at the Yellow –
Elevated level. Other than this initial assessment announced in early March, we have received no
other advisories or updates as to the current HSAS threat level.
Recommendation:
a. As a component of the HSAS system, establish a scheduled daily update, disseminated using
NAWAS and Law Enforcement Teletype, etc., to include the location of the current region,
state(s) threatened. It can be assumed that at various times more than one state or region of
the nation may be at greater risk of attack. Because of the fluid nature of terrorist threat
information, a daily national update enhances regional and national situational and
operational awareness.
b. No less than weekly, review the threat level, adjust as necessary, and inform all states.
Prolonged periods of readiness at the higher levels can be economically challenging at all
levels of government. Hence, the need to back-down the system to a lesser threat level, as
soon as intelligence shows it to be a prudent measure.
8. Presidential Directive #3 states, “Threat Conditions shall be assigned by the Attorney General in
consultation with the Assistant to the President for Homeland Security.”
Recommendation: This statement is adequate if the threat is general in nature and not specific
to a particular state or region. However, the Attorney General should consult with, and seek the
advice of the Governor(s) and Directors of Homeland Security of those states/regions where a
specific threat exists, before assigning a threat level.
9. The recommended protective action guidelines for HSAS Threat Level RED - SEVERE, are such
that extraordinary measures may be warranted by the state and region that is threatened. Such
measures are inherently expensive and therefore could not be bourn for any substantial period of
time, by a state or local jurisdiction. The Stafford Act, and the Federal Response Plan dated
04/99, allow for the President to issue a Presidential Declaration of Emergency, in advance of
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impending severe calamity. This allows the President and Federal Agencies to use extraordinary
measures to address resource needs to mitigate the event before it occurs.
Recommendation:
a. The National Office of Homeland Security should recommend that the President issue a
Presidential Declaration of Emergency any time the threat level is designated RED –
SEVERE, to allow for the pre-positioning of federal response assets.
b. If a state or local jurisdiction is designated as the potential target area under a RED –
SEVERE level, that state or jurisdiction should be allowed to capture the costs of
extraordinary measures, and seek reimbursement from the Federal government.
c. Declaration at the RED SEVERE level should include procedures to issue a Presidential
Declaration of Emergency for the region(s) impacted within 24 hours of the initial
notification.
Don Miller
Washington State
Comment 3
Federal Signal Corporation has reviewed the existing Homeland Security Advisory System from three
different perspectives: the colors scheme used, the number of warning levels used to communicate the
nature and degree of terrorist threats, and the effectiveness of the color messages communicated to the
public.
A review of the color scheme used reveals three colors that are very familiar and encountered on a daily
basis by the general public - red, yellow, and green. These colors are used in traffic lights that comply
with the guidelines administered by the National Transportation Safety Administration. Where green is
used to communicate to motorists that it is safe to go, yellow means proceed with caution, and red means
stop. The Homeland Security Advisor System has added two additional colors of orange and blue to this
already familiar system. The addition of orange placed next to yellow makes it difficult to distinguish
between these colors in position and color conspicuity. This is not only true on paper but also in real life
application. This makes it difficult for observers to effectively identify which level of threat is currently
active. A second color issue is the use of green and blue. It is difficult for the color-blind population to
distinguish between these two colors. If it is determined that a tied color scheme is the most appropriate
system to communicate the threat of an event then Federal Signal Corporation recommends a minimum of
three colors – red, yellow, and green. Where green would mean an all clear indicating no immediate threat
currently exists, yellow would mean there is a watch indicating conditions are correct for a threat to
occur, and finally red would mean a warning indicating an event that threatens life or property has been
identified or is in action.
The number and levels of warning exceed that of any system currently in place. It is Federal Signal
Corporation’s experience and belief that the more levels you add to a visual or audible warning system
the more confusion you will create for the general public. This type of multiple tiered warning systems
may be more applicable to first line response authorities and agencies that are trained on a regular basis to
understand the warning levels and how to respond to them. For example, the military has established a
four-tiered base warning system using the names of Alpha, Bravo, Charlie, and Delta. Each level requires
different procedures to be followed and also increased security measures to be implemented. The
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Homeland Security Advisor System is more closely associated with the military system currently in place
with the addition of one more level. A system introduced by the National Weather Service uses a two-tier
verbal method for warning the public. The first level is a watch, which indicates conditions are right for a
severe storm. The second level is a warning, which indicates a severe storm has been sighted or is in
process. When there is no threat of a severe weather condition no warning is used. This system is most
familiar to all citizens and used throughout the United States. The Office of Homeland Security has
introduced a visual warning system with five levels. The general public has already been conditioned by
the National Weather Service to be responsive to two levels of verbal warning. The challenge for the
Federal Government will be to condition the general public on how to react and respond to a five tier
visual warning system that provides limited detail on the nature of the threat and what to do. Federal
Signal Corporation believes the real challenge is going to be one of implementation and training.
Realistically what is the general public going to do differently at each of the visual levels? Do they
respond differently to an elevated or high-level indicator of yellow or orange?
If the proposed system was actually in place today, how effective would the message be and how would it
be communicated to the public? The general concern here is that it would lose its meaning. For example,
as a Nation we are currently at a level yellow, which means elevated. What have any citizens done
differently in their normal day-to-day activities to respond to this level of threat? If the United States
remains at this level over the next year with nothing changing the yellow level will become the norm for
all practical purposes and become a low risk or green.
How is the general public supposed to gain access to the multi-color level warning system? How will they
know if it changed and if it did what should they do? What about the consistency of finding the
information from one city or state to another? Will the place a citizen goes to get access to the
information be the same in Washington, New York, San Francisco, and Chicago? Visual warning systems
require direct line of sight to be effective, which makes it difficult to produce for mass media alerting.
Audible warning systems can reach greater masses of the population and can be directed towards specific
areas through radio receivers or audible devices strategically placed throughout a city, county, or state.
Audible warning signals that are complimented with verbal messages contain more specific information
on the event and what to do are most effective.
The visual warning system introduced by the Attorney General is only part of a total solution that needs
to be redefined and integrated into existing warning systems to create an effective means of
communicating the nature of an event and an appropriate response desired as a result of the threat. The
system or national framework should be used to effectively communicate all potential exposure risks to
the public which not only include terrorist threats but also include severe weather, flood, hurricane,
chemical spill, military, nuclear fall out, and war.
Greg Sink
FEDERAL SIGNAL CORPORATION
Comment 4
THOMSON, the parent company for Technicolor, RCA, Grass Valley, Atlinks, and General Electric
consumer telecommunication products, would like to respond to the color-coding HSAS studies:
Over the past nine months, major worldwide manufacturers (including THOMSON, Phillips, Samsung,
JVC, Radio Shack, SIMA, Midland, Reecom, Sharp, Funai, TFT, Mitsubishi and
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Hy-Tek) have created a new technical standard, name, and trademarked industry logo for "Public Alert"
devices. The largest worldwide consumer electronics industry group, the Consumer Electronics
Association (CEA), manages the trademark and certification program for this new 2004 product standard.
This new product standard was reviewed during CEA committee sessions in early October, and additional
CEA 'Special Interest Group' members reviewing 'Public Alert' devices include Microsoft, Sony,
Kenwood, Grundig, Uniden, Russound, and others.
The new Public Alert device standards were created after more than 3 years of development work by
major manufacturers, and following thousands of hours of behavioral studies and consumer and
institutional testing with actual working prototype devices, and at hundreds of U.S. locations.
Public Alert devices are the first public alert devices to respond beyond even the "all hazard" EAS public
alerts. In addition to responding to localized neighborhoods to avoid annoyance alarms, (requirements state
they must use digital data to selectively target, reducing the huge EAS broadcast coverage areas), Public Alert
devices can be set to trigger even when "off" (such as a radio in the "off" position). Targeted response with
24/7 monitoring, and four alert-level indicators.
Unlike simple weather radios, Public Alert devices are designed to avoid annoyance, triggering more
accurately, using digital data signals, not analog transmitted tones. They also do not trigger audible alerts
during weekly or monthly tests, and many have multiple audible options, including silence modes and
chimes --- in addition to sirens and voice data. Some offer multiple language decoding (French-Spanish-
English), and on-screen text for the hearing impaired --- neither presently possible with consumer EAS
devices. And unlike EAS, they pass 100% of
all issued alerts ---- tailored to the needs of the user, not the broadcaster. The first certified products
(radios and TV's) will reach retailers and the public in February or March of 2004.
In addition to responding to all EAS alerts (such as NOAA alerts for tornados, flash floods, avalanches,
blizzards, forest fires, hurricanes, tsunamis, volcanoes and earthquakes), they respond to FEMA national
attack alerts, terrorist attack alerts, and other life-threatening emergencies. Additionally they include
new "all hazard" capabilities beyond the present EAS event codes. In addition to AMBER child
abduction alerts (partially functional under EAS), the Public Alert standards were created jointly with
Canadian government agencies ---- establishing the first cross-border compatible, and worldwide platform
standards for public alert dissemination in North America --- and by mid 2006 some international areas.
Joined by Department of Commerce officials (NOAA, National Weather Service), FEMA, and
Environment Canada and Industry Canada officials, the CEA Public Alert standard defines the minimum
audible and visual alerts for more than 70 alerts. Alert response codes in Public Alert devices, but not
available in the EAS system include: Biological Hazard Warning, Boil Water Warning, Chemical Hazard
Warning, Dam Break Warning, Contagious Disease Warning, Flash Freeze Warning, Food
Contamination Warning, Industrial Fire Warning, Land Slide Warning, Power Outage Advisory, Wild
Fire Warning, and others.
Public Alert' standards can be adapted to many "reception" devices including stand alone radios,
televisions, home security systems, and office and residential phones. For certification and use of the
logo, devices must match a detailed technical standard established and defined by CEA. In addition to
audible tones (such as chimes, sirens, voice), all 'Public Alert' video devices must contain a series of
indicator lights:
Green indicator: Labeled READY and illuminated when properly receiving and monitoring
the emergency alert transmission, but with no active alerts.
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Yellow indicator: Labeled ADVISORY and illuminated when an ADVISORY level alert is issued.
Orange indicator: Labeled WATCH and illuminated when a WATCH level alert is issued.
Red indicator: Labeled WARNING and illuminated when a WARNING alert level is issued.
This standard means by mid 2006 millions of consumer electronic products will have these standardized
call-outs. Already thousands of pre-certified products (including the new RCA Alert Guard televisions,
refer to www.rca.com and highlight Alert Guard) have shipped over the past 60 days with these same
color indicators.
In research conducted by THOMSON (Scott Kendall is a THOMSON Experimental Psychologist and
also a co-inventor of our Alert Guard system), we found that the colors green, yellow, orange and red
meant something to the public in terms of the degree of danger. While green is good, red is bad (or hot).
Scott Kendall noted "Blue means cold and is not widely understood to mean anything relating to danger
or alertness. The Public Alert standard with green being good and red being bad has been strongly re-
enforced with traffic indicators. Green means go through the intersection, as everything is clear. On road
signs green is used for information that causes the driver no threat. Yellow is reserved for road signs that
indicate a road feature that could cause an accident if not acknowledged. Orange is for road construction
and is an elevated alert that there could be people or machinery in the roadway. Finally, red is reserved
for red lights, stop signs and break lights. Red means you must stop and use a high degree of caution or
an accident will surely occur. Other colors such as purple, black, white, and brown do not carry meaning
for the general public. Black might refer to death, but it might also be seen as racially derogatory. Black
and white are also not colors easily expressed since so many things are in black and white, it might mean
nothing depending on how it is displayed."
The new CEA Public Alert category standards have used the four colors in a scale having a specific and
operational meaning. Four adds to the simplicity, and categorizing new alert events to matching alert
levels is made easier, with clear and distinctive alert levels. Using terms like, "elevated", "high", and
"severe" leaves doubt and requires interpretation. And using too many colors is confusing, and reduces
the distinction. Four colors are manageable for the general public --- five overlapping categories are not.
Based on using the same four colors as CEA 'Public Alert' devices (the industry standard), we would
recommend that the HSAS threat colors correspond to:
Green - "Good" There is no intelligence information that any terrorist event will
happen in the next 7 days. (All clear)
Yellow - "Advisory" There is some unconfirmed intelligence information that a terrorist
event may happen in the next 7 days. (Inconclusive or developing reports)
Orange - "Threat Watch" There is specific or confirmed intelligence information that a
terrorist event will happen in the next 7 days. (High probability to specific threat)
Red - "Attack" A terrorist event is in progress. (Occurring)
Both Scott Kendall and myself (John Merrell) can make ourselves available should further input be
required. We both participated in CEA sessions, including the Working Groups on technical standards
and certification programs. Nathan Ridnouer (Senior Manager with CEA) can be reached at CEA's
offices in Arlington, Virginia at 703-907-7600. My office phone is 317-587-5025, and Scott Kendall's is
317-587-4399, both at THOMSON's America's headquarters in Indianapolis. We share extensive work
with public and government agencies on public alert communication over the past several years in
developing systems for satellite, broadcast, cable, broadband, HDTV, and telecommunications systems.
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John Merrell
THOMSON
Comment 5
Thank you for the opportunity to comment on the Homeland Security Advisory Service (HSAS).
By way of background, I am a board certified consulting meteorologist and a Fellow of the American
Meteorological Society. In 1992, I received the Society’s highest award for applied meteorology in part
because of innovations in storm warning services. In 1981, I founded WeatherData, Inc., a weather risk
management company. Prior to WeatherData, I was a television meteorologist in St. Louis, Oklahoma
City and Wichita. Because of my work in conveying the threat of storms and other high-impact weather
to the public, I believe I am qualified to comment on the HSAS.
My best advice: Discontinue it.
Unlike a tornado watch or tornado warning, there is no possible metric by which the success of the HSAS
can be measured. In meteorology, there is a complete absence of a tornado watch or tornado warning on
all but a handful of days per year. When there is a threat of tornadoes exists a watch is issued which is
escalated to a warning when a tornado is imminent.
In order for the HSAS to have the level of credibility of the tornado watch and warning program the
HSAS would have to be at green all but two or three days a year, go to yellow the day before an attack
and then red prior to the attack occurring. Then, the day after the attack, it would have to be back to
green. Even if it were somehow possible to anticipate an attack with this level of precision, I believe we
would all acknowledge that, politically, this would never occur. In fact, I do not believe the HSAS will
go to green in my lifetime.
Even if we could somehow know in advance for certain that an attack was going to occur, the government
could not specify the threat with enough type, location and time specificity to allow those actually
threatened to protect themselves and those not threatened to go about their normal activities. I am certain
that if the government knew about an attack with that level of specificity, the attack would be thwarted,
meaning the alert would be a false alarm.
All the HSAS has done so far is ratchet up anxiety. I recommend it be discontinued in favor of simply
providing specific information about the threat and potential protective actions to the news media for
broadcast during periods of heightened threats.
Michael R. Smith, C.C.M.
CEO/Founder
WeatherData
Comment 6
In response to your questions, I submit the following comments regarding the Homeland Security
Advisory System (HSAS).
1. When the threat level changes, I am always made aware by the media first. “Official” notification can
lag by hours or even days. I generally receive no additional information from either the State of
California or federal officials regarding any specifics.
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2. The current HSAS is not an effective means of communicating risk. The categories are too vague to
provide any actionable guidance. The distinction between the various levels is not clear and is not based
on objective measures. The use of so many colors has created an infamous lack of credibility.
It’s not clear that the PPW initiative will go anywhere. Media reports indicate that DHS isn’t going to
make any major changes soon.
http://news.yahoo.com/news?tmpl=story&u=/usatoday/20031107/pl_usatoday/11941687
I generally agree with the PPW feedback letter of April 2002. However, I would not support the use of
multiple color systems despite the need to further qualify threat descriptions. The use of a color and a few
key words may be the best bet.
Chris Godley
Comment 7
With regard to the proposed recommendations for enhancing the current EAS system, I offer the
following comments.
While recognizing that incentives to encourage participation by broadcasters and cable operators
are vitally important, I also feel that "EAS" should not, once again, overlook the key role that
the local emergency manager has in the successful implementation of EAS warnings by building
relationships on the local level. I would encourage special incentives and recognition for the
local emergency manager's successful EAS efforts - much like communities that achieve the NWS
"Storm Ready" certification.
I also, fully support the idea of working towards national standards to "link these new
technologies and digital systems to EAS and NWR", however I would encourage that important existing
technologies do not get overlooked when advancing national standards.
As a siren manufacture, I question why sirens, are not an integral part of the autonomous EAS
activation's for specific events (like EAS-NWR radios) using nationally standardized signals.
Tom Cypert
American Signal Corporation
Comment 8
The Emergency Management Association of Texas (EMAT) welcomes the Homeland Security Advisory
System proposed by the Office of Homeland Security. Since local government officials are the first to be
called for information in times of crisis, we believe that it is critical that these local officials be notified
well in advance of public release. A minimum lead-time of two hours should be established. Longer
lead times are desired, but the two-hour minimum must be held inviolate except in the most extreme
cases. The published information does not state how the protocol to contact local government will be
established. How will the Department of Justice determine who in local government needs to be
contacted when these Advisories are issued?
It is not clear what tool will be used to disseminate a change in Advisory Status. Is DOJ going to place
phone calls to the impacted governments? Will it go through the State Governments and expect state
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government to relay the information? EMAT would strongly support providing the information directly
to local governments at the same time as state governments are notified. EMAT does not feel that using a
“pass through” system of DOJ notifying state governments who in turn notify local governments is a
viable method.
Will the Attorney General go directly to the affected local governments, or will there be some type of
electronic notification? If electronic notification is selected what level of redundancy will be in place?
There seems to be an implication that it could be issued to certain industries, it is not clear if it will go to
these industries and possibly bypass local government. The mechanism to determine who should receive
these notifications is not clear. EMAT strongly believes that if an industry receives a notification that the
corresponding local government units be notified as well.
The recommended practices cover what government and private sector entities should do, but do not
cover actions by the general public. When a tornado warning is issued, there is clear guidance to the
public as to what actions we expect them to take. There are no such actions listed in the information
released by the Office of Homeland Security. EMAT understands that each incident can dictate different
actions, but establishing guidelines for local government on what actions to take with respect to the
general public needs to be addressed. From the information provided to date it is not clear what a local
government official should do when a Severe Condition is declared. Would this dictate for example that
all public gatherings, concerts and places of entertainment be closed? Should local government
preemptively declare a state of emergency (or appropriate wording according to their local disaster laws)?
Should business and industry be ordered to close and all but the most critical employees required for
public safety and welfare told to stay in their homes, or perhaps evacuate an area?
Providing additional guidance in those areas would take the program to the next level in protecting lives
and property within the United States.
Emergency Management Association of Texas
Comment 9
As an Emergency Manager and former military member, I feel the advisory system is a very good idea.
However, I do feel it is a little confusing and should be aligned
along the same systems used by the military. Alpha-Delta. By having a common system and guidelines
for responses, it would make everything more simple to follow.
Rodney Andreasen
Director
Jackson County Emergency Management
Comment 10
Question #1: Receipt of info: Officially, we get our information via the Florida State Warning Point
(ESATCOM and E-mail). Unofficially, via http:\\Emergencyemail.org to our cells, digital pagers and
email.
Question #2: Actions taken when threat increases: Key gov't agencies may meet depending on the nature
of threat. In any case, we'll send a public advisory to the media, public safety agencies, activate our blast
fax, initiate Emergencyemail.org messages.
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Question #3: When the Fed gov't changes ....additional info: We haven't received much follow up
information. We mostly rely on FoxNews for "the rest of the story".
Question #4: Is the current Homeland Security Advisory System...effective? Somewhat, because we're
going to get some information. It's not the best system out there!
Last two "bullet" Question sections: Recommend we use what's been tried and proven. Recommend you
use the system developed, tested, and complies with Incident Management System 's common
terminology.... use the DoD's THREATCON system. That system allows for a broad threat warning,
recognizing the local threat and allows tailoring it to the local environment. Where there is a military
installation nearby, this would allow consistent information and awareness for the community. After all,
when a military installation (target) is in the area, internal and external counter intelligence and
antiterrorism agencies should be communicating with one another. (We've broken down the barriers
between Federal investigative agencies, why not take the next step and let the community work together
when it can?)
Richard A. Zyvoloski Jr, KG4WSG, CEM, FPEM
Coordinator, Collier County Emergency Management
Comment 11
The usability of the current system for various types of threats is severely limited due to the fact that there
is a single warning group. If the system supported closed user groups (i.e.: airport infrastructure, water or
power utilities, police, national guard etc) then it would be possible to tailor the types of message sent and
offer greater amounts of information without providing non required information (SPAM) or non
impacted groups.
Messages should include specific text with key words or instructions depending on the initiation event for
the alert or change in security level.
Systems for distribution of alert messages in place today are insufficient and desperately need to be
upgraded.
Current public notification systems, such as the Emergency Alert System, were designed in
the 1960’s, utilizing technology of that time. It is widely agreed that the current emergency
alert systems are not effective and must be updated. In fact, Ken Allen, Executive Director of
The Partnership for Public Warning, put it very directly by stating, “the current system
simply does not work”. Presently, Americans rely on commercial television, radio, weather
radios, telephone dialer systems, sirens or highway signs to learn of emergency situations. At
any point in time:
• About 31 percent of the population may be watching television.
• About 22 percent of the population may be listening to the radio.
• Less than 20 percent of the residents may be near an emergency alert siren.
• Less than 13 percent of households have weather radios.
The current Homeland Security Advisory System generally provides a single level of threat for the entire
nation. Should the system be revised to provide tailored threat levels for specific geographic regions or
other types of targets?
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STC: YES!!
If yes, what revisions would you recommend to achieve this objective?
STC: If we are to implement a true 21st century emergency alert solution, we cannot
continue to rely on traditional 20th century alert technologies. We should challenge our
current deeply engrained paradigms of how alert messages are delivered and explore new
means of getting information to the public. We must develop ways other than our current
broadcast mediums of radio, broadcast TV and the cable industry for ways to deliver
alerts. Statistics show that these means are not adequate in crisis situations. We need to
use creative means of delivering messages that do not cannibalize the transmitting entities
primary revenue sources or are overly intrusive to their business. Warning receivers
should be included in many different types of consumer electronics devices that self-
activate in times of crisis. The advancements in our all hazards warning systems must be
cost effective, scalable and where possible utilize existing automated high-speed digital
infrastructures.
What changes, if any, would you recommend to the Homeland Security Advisory System?
STC: Using current technologies and EAS paradigms, broadcast and cable operators
must sacrifice critical broadcast time in order to deliver alert messages. This can cause
loss of commercial revenue from advertisers or lead to customer dissatisfaction. As
such, broadcasters and cable operators are often hesitant to participate in EAS
programs. We should leverage approaches that automatically distribute emergency
information via methodologies that are not dependent on human intervention. These
processes should be minimally intrusive and not cannibalize the revenue sources of
the distribution entity.
Efforts should be made to create and to foster systems that allow delivery of alert
messages with minimum impact to the revenue stream of broadcasters, cable operators
or telecommunications systems operators. Whenever possible, such systems should:
1. Not utilize revenue generating features or bandwidth
2. Support the delivery of very targeted delivery areas, thus minimizing the potential impact
on broadcasters.
George Lamb
Safety Through Cellular
Comment 12
Thank you for the opportunity to comment on the Homeland Security Advisory System. I will make my
comments in each of the four areas requested.
(1) When the threat level changes, how do you receive that information? What actions do you take when
the threat level goes up? When the federal government changes the threat level, do you receive additional
information or instructions from other local or state authorities?
Information is received from multiple sources - broadcast media, California Office of Emergency
Services, California Emergency Medical Services Agency. My agency (the Local EMS Agency)
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passes this information on the local hospitals and ambulance services, but takes no other action.
Additional information or instructions is usually not received or is nonspecific.
(2) The Homeland Security Advisory System was established to provide a comprehensive and effective
means to disseminate information regarding the risk of terrorist attacks to Federal, state and local
authorities and to the American people. Is the current Homeland Security Advisory System an effective
means of informing the public? If yes, please describe how it has been effective. If it is not effective,
describe the reasons why not.
No, the existing Homeland Security Advisory System is not an effective means of disseminating
information regarding the threat level. (1) First, the Advisory System makes no distinction for
different geographic areas or for different types of threats. (2) Second, it does not provide advice
to the public or to emergency response agencies as to what actions should be considered. The
result is that the public largely ignores the advisories, while public safety agencies incur step up
all levels of surveillance and great cost. (3) There is a perception, whether correct or not, that the
warning system is based on very crude intelligence (e.g., level of "chatter"), lack specific criteria
for different levels, and is somewhat politically motivated (e.g., would a level orange be issued
during the Christmas shopping season?). (4) Fourth, it appears that we only have two alert levels
- yellow and orange - and that the advice to the public is the same for both.
(3) The current Homeland Security Advisory System generally provides a dingle level of threat for the
entire nation. Should the system be revised to provide tailored threat levels for specific geographic
regions or other types of targets? If yes, what revision would you recommend to achieve this objective?
Yes, the system should be revised. My recommendation would be to eliminate entirely the colors
or alert levels and, instead, issue specific advisories based upon the information available. Such
advisory have been issued in the past regarding air travel, especially overseas, and are issued by
the State Department for travel to foreign countries. Even if the information available to
Homeland Security in a specific situation was vague, it would be more beneficial to just come out
and say that were was indication of a nonspecific threat, or that there was indication of a threat
involving transportation, or that there was indication of a threat involving a major port, or that
there was an indication of a threat involving Disneyland. We actually did receive information a
few months ago about a potential threat involving one of several bridges. That information was
much more useful than a change in the color level. (Interestingly, there was no change in the
color level associated with that warning - we remained on Yellow.) Information should be
provided in a manner that encourages public confidence in the advisory system. If there really is
credible information indicating that a specific terrorist act might occur, that information should be
given to the public even if it would have a negative economic impact. We currently do that
locally with such things as bomb threats. Some facilities are used to receiving many bomb threats
and have developed criteria for distinguishing between non-credible and credible events. This
avoids undue disruption of activities while assuring that public protection is accorded high
priority. Homeland Security could develop similar criteria and a process removed from political
consideration for issuing advisories.
(4) What changes, if any, would you recommend to the Homeland Security Advisory System?
Eliminate the current system of issuing nationwide alerts based on vague threat levels and replace
it with a system of issuing carefully worded advisories based upon credible information. These
advisory might range from fairly generic (e.g., "We are seeing a significant increase in 'chatter'
among individuals and groups thought to be associated with terrorist activities, but have no
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information on a terrorist threat at this time.") to fairly specific (e.g., "While we are unable to
confirm any details, we have information of a terrorist threat to a passenger airline departing an
East Coast airport bound for a foreign location, possibly
occurring over this Labor Day holiday.)
Art Lathrop, Director
Contra Costa Emergency Medical Services
Comment 13
The City of Tulare receives its information on a change in the HSAS through the County OES office,
International Association of Fire Chief's (IAFC) and lastly the general media. When the threat level goes
up, we do adjust some operations. An example is that when we are at the "orange" level, we restrict
access to our fire stations and apparatus. We do not allow anyone other than employees or immediate
family members to come into the living areas of the station. The general public is restricted to the
business office and we do not permit "ride-a-longs". When the threat level is changed, we often do not
receive any additional instructions from the State government.
While it might work to inform the general public, I think much more is needed in being specific with
information to the authorities. The general notice to the public probably helps to explain to them why
they are seeing additional precautions, but most of the public could care less, until they see an act of
terrorism.
Yes, the system should be revised to provide tailored threat levels for specific geographic regions and
other targets. I would recommend that they be further divided up into states, then OES regions, then
counties or even cities. If there is a specific target known, then the public agencies involved should
receive a classified, specific briefing from the DHS.
Lastly, it does no good for the threat level to be raised across the United States, unless it has the potential
to impact the entire United States. Increasing the threat level on the west coast when let's say, New York
City is the determined target causes unnecessary precautions and cost. My other concern is that the public
in general may become accustom to the levels being raised and start to ignore them all together.
I believe that the HSAS concept is good, but that it needs to be specific. I would also like to see a master
list from each city or county on who is to be notified and make sure those persons are contacted in a
timely manner, before it comes out to the general population. The notification process is inconsistent. I
sometimes get the notice of an elevation in the HSAS well after the general media has already put it out.
It would also be helpful if we as a local agency could contact a representative (from HSAS or DHS) to see
if there is a specific threat to an upcoming event. It would also be helpful that if the local agency had
information on a potential threat, we would know who to pass it onto at the state and federal level.
Michael Threlkeld
Fire Chief/ Emergency Operations Center Director
City of Tulare, California
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Comment 14
Current Threat levels are not easily known. Should be incorporated as part of radio and television station
identification at least once per day, more if threat is yellow or higher. Specific instructions as to what
people should do at each level or very sorely needed, otherwise altering people to varying levels has little
impact.
Michael Frenn, Agency Administrator
Solano County Emergency Medical Services Agency
Comment 15
Comments from Contra Costa County, CA are attached (minus attachments)
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