Jeng Mao
Public Safety Program
National Telecommunications and Information Administration (NTIA)
US Department of Commerce
Room 4624
1401 Constitution Avenue NW
Washington, D.C. 20230

Re: All-Hazard Warning - Comment, Docket No. 000609173-0173-01

As chairperson of the Public Private Partnership Committee of the International Association of Emergency Managers (IAEM) as well as a regional president of the same organization, I am writing to provide some comments related to recent discussion of the use of new technology for delivering hazard warnings.

Dissemination of warning information to individuals in communities ranks high on the list of priorities for emergency managers at the local government level in support of state and federal programs. Any activity, especially the use of new technology, that will improve the ability of the emergency management coordinator to give additional lead-time of an impending event or immediate information post event will help in reducing the potential loss of life and/or injury as well as reduce property losses.

Although several methods of hazard warning have been in place for more than twenty-five years, i.e., the NOAA WeatherAlert Radio and the Emergency Alert System, it is always appropriate to earnestly review new technology that would allow members of the emergency management profession to reach more people more quickly during times of need. It is prudent, however, to review the new technology with the caveat that local programs are not consistent throughout the United States. Although efforts are being made in the emergency management profession to elevate the level of program activity in all communities, the reality of restrictions faced because of personnel availability or fiscal resources may make it temporarily not possible to maximize the benefits of some of the quantum leaps of technology in computers and wireless communication that have occurred in recent years and will likely continue in the years ahead. This being said, the International Association of Emergency Managers welcomes the opportunity to be involved in this discussion.

In many communities, including my own, the use of pagers and computerized phone notification systems is already in place to warn the general population of emergency events. Some communities, again I use mine as an example, have 800 mhz radio systems and pager systems to inform the media of events which might impact the community. I am fortunate to also have an e-mail distribution through my website to provide information to interested subscribers; I don't believe this practice is widespread, but it would perhaps warrant further discussion and review as part of the committee's activities.

In addition to the sound structure of communication between NOAA and emergency management, other communication bridges have been or are being developed at the federal, state, and local levels not only between public safety agencies but also with private sector companies that can provide new or updated technology. The telecommunications industry has been one of the most proactive groups in recent years and has much to offer in supoprt of our programs. Some of the technology advances have reduced the workload of local emergency management coordinators and some of them have, of necessity, increased the workload, but the use of technology has generally been welcomed in localities where effective local programs are in place. Conversely, some of the best technology has not been able to be effective in areas where there was not adequate local support.

The economic considerations involved in the current discussion by the committee will hopefully not be a significant impediment to the application of the technology. Research has shown that the socio-economic costs of trauma can quickly far outrun the cost of technology use or other mitigation activities that could have reduced the impact of the event. The implementation of cellular phone surcharges in support of 911 Operations is becoming commonplace throughout the United States. The purchase of weather radios by individual citizens and businesses is evidence that residents in a community are willing to personally shoulder some of the costs involved with hazard warnings if it is demonstrated that the benefit is greater than the cost. As technology is developed and additional manufacturers and service providers in the marketplace are identified, the product cost should decline and further eliminate the economic impediment.

Currently, a large number of emergency management agencies rely on the NOAA broadcasts as the "official" mechanism to notify the residents of 'their community. The NOAA broadcasts direct the person hearing the broadcast to turn on their radio or television for further information. This is similar to the way that outdoor warning siren programs are marketed as a means to advise people to go inside and tune in to local media outlets. I am not aware of specific legal requirements in this area, but discussion would be prudent about the use of the new technology as a warning mechanism should the notification not be disseminated to all of the residents for some reason. As I stated earlier, the possibility of a problem in the use of the new telecommunications technology whether it be in technological, economic, or legal area of concern should not be cause to not rigorously evaluate the service.

The potential use of new technology to improve our ability to provide timely all-hazard warnings to the public is of great interest to me and other emergency management professionals. Programs that are developed should be intended for nationwide use to maximize the potential benefit of the program and minimize the cost to any one community in particular. Nationwide programs developed by "parent companies" rather than individual programs developed with local vendors when and where possible will also reduce confusion among the general population which tends to be very mobile.

Effective emergency management professionals utilize a "toolbox" of resources to maintain and hopefully improve their local programs. On behalf of the International Association of Emergency Managers membership of approximately 1500 individuals from both the public and private sector, I would welcome the opportunity to discuss this matter further with the members of the committee. Taking this level of interest a step further, the association would like to request that a representative of IAEM be added to the panel in order to provide input on the matter. We believe this participation would compliment the other members of the panel, such as the Institute for Business and Home Safety and the American Meteorological Society, with whom we currently interact on a regular basis.

I will look forward to your response to these comments and request for participation by the September 1, 2000 due date you have identified. Thank you again for the opportunity to participate in this very important discussion.

Sincerely,

Robert G. Goldhammer, CEM
IAEM Region VII President
IAEM Public Private Partnership Committee Chairperson

Contact Information:

International Association of Emergency Managers (IAEM)
111 Park Place
Falls Church, VA 22046-4513
Phone: (703) 538-1795
E-mail: iaem@aol.com

Polk County Emergency Management Agency
111 Court Avenue
Des Moines, IA 50309
Phone: (515) 286-2107
E-mail: polk.county@emd.state.ia.us