Telcordia is providing a formal response to the "All-Hazards Warning" Roundtable meeting held on July 17, 2000. Dr. Barbara Reagor, General Manager for Telcordia's "Community Notification Solutions" organization and product represented Telcordia Technologies on the roundtable.

The National Telecommunications and Information Administration (NTIA) of the Department of Commerce has requested that interested parties submit written comments on any issue of fact, law, or policy that may inform the U.S. Department of Commerce on hazard warnings. Specifically, comments are requested on the questions below. These questions are designed to assist the public and should not be construed as a limitation on the issues on which public comments may be submitted. Comments should cite the number of the question(s) being addressed. Please provide copies of any studies, research and other empirical data referenced in the comments.

The Questions are:

1) Is it technologically feasible today to deliver hazard warnings: to wireless devices, such as cell phones and pagers; over the Internet to users who are online; to standard telephones in the form of a call warning; to broadcast television; to satellite services; to cable television; and to emerging and developing technologies?

2) What are the tradeoffs among technology options?

3) What are the economic impediments, if any, to the use of any of the technologies that might be used to disseminate hazard warnings?

4) What are the legal impediments, if any, to the use of any of the technologies that might be used to disseminate hazard warnings?

5) What legal measures, if any, should be taken to foster the delivery of hazard warnings?

Today, the expectation of a disaster-free environment is unrealistic. And yet, as we listen to the news and read the papers on the aftermath of tornadoes, hurricanes, nor’easters, snowstorms, terrorism, ----, we are continually faced with the reality that current emergency alert systems are not meeting the needs of the Public. FEMA has developed a Public and Private Partnership for the creation of Disaster Resistant Communities. Telcordia is a Project Impact National Partner. Over the last 5 years Telcordia conducted an assessment of current technology and conducted research to determine the feasibility of the development and commercialization of a Community Emergency Notification Telecommunications System referred to as Telcordia™Community Notification Solutions. Telcordia chose to conduct this development due to the following:

• Broad Expertise in Telecommunications
• Broad Expertise with Disaster Preparedness, Response and Recovery
• Current Activity in Standards and Requirements and Developed Class Services
• Current Activity in Local Number Portability and E911
• Current Expertise in Wireless, NGN, VOIP, Internet, Cable

Emergency officials are currently without a universal acceptable means of notifying the public of current or imminent danger. "The nation needs to develop a comprehensive model for warning the public, provide it to local communities along with technical assistance, and even out the degree of protection provided by warning systems for all citizens" Dennis Miletti, Disasters by Design, 1999.

Emergency Officials consider an effective alert system to be

• Speed of Delivery

- Everyone in less than 15 minutes - any size or shaped area

• Delivery Specificity

- One house, block, borough, town, city, military base

- Tornado track, coastline, flood zone, service road

- Customers served by single water main, gas main, sub-station

• Message Effectiveness

- Immediate awareness to all present

- Clear and concise communications

- Event record for confirmation by others

The results of our own studies to date have indicated there is a growing nationwide NEED for Community Emergency Notification, and the Community Notification Solutions System is feasible and affordable, and that Telcordia can help to develop and integrate it into the PSTN (Public Switched Telephone Network) and existing Public Safety networks.

Recently, Telcordia announced a new business focused on short messaging—Telcordia Community Notification Solutions. The solutions will be used for emergency notification, community information delivery, new communication services (such as e-mail notification and unified messaging updates), subscription information services such as a daily weather forecast, and commercial messaging delivery such as a doctor appointment reminder.

Communities currently rely on a number of methods for emergency notification, including radio and TV broadcasts, door-to-door notification, sirens and telephone callout systems. In many communities, the leading notification procedure is a loud speaker mounted on a fire truck or police car. Telcordia developed Community Notification Solutions in response to a growing demand for a solution that is targeted and can also provide rapid message delivery with improved message comprehension.

The wireline telephone network provides the ability to deliver messages to a specific customer line/single geographic location, specific customer lines/specific call lists, and to nearly 100% of all locations within geographically defined areas of any shape or size. Telcordia ™Community Notification Solutions technology maximizes the performance of the wireline telephone networks short messaging capabilities providing a combination of speed, capacity, specificity, efficiency, and message effectiveness not currently attainable with any technology. Community Notification Solutions technology, when combined with the latest in geographic information system solutions, meets the demand for public safety officials to quickly, effectively, and efficiently notify people in harms way.

The demands of public safety notification can provide market saturation (+95%) of Community Notification Solutions in areas served. Telcordia is working with public officials whose intent is to provide service to every home, business and institution within their community. Market saturation creates a wealth of new messaging opportunities to service providers, and the private and public customers they serve. Systems, based on Telcordia technology, could also provide non-emergency notification benefits. School closings, utility outages, water restrictions, and appointment reminders, for example, can be communicated through these systems.

Residing on the existing and very reliable telecommunications network, Telcordia Community Notification Solutions maximize the network's capacity and capabilities for notification. With a small enhancement to current public safety products, emergency officials will be able to send digital messages through the telephone network using current switch features, and without ringing telephones. The signals are received by inexpensive notification devices that can sound alarms, flash colored lights, and display and store time-stamped messages, as instructed by the message sender.

Telcordia ran a successful test of the community notification technology in the spring of 1999 in Deerfield Beach, Florida—the state's showcase community for emergency preparedness. More than 200 residents volunteered to test Telcordia Community Notification Solutions for two months. The volunteers received simulated emergency notifications and provided resoundingly positive feedback to Telcordia.

Telcordia is currently preparing two demonstration sites as a final step prior to commercialization – an evaluation of the product requirements. Working with FEMA, Tennessee EMA, Lincoln County, City of Fayetteville, BellSouth, Lucent, Dialogic Communications Corporation and ClassCo, Telcordia will run a demonstration site in Fayetteville TN through the fall 2000 season. Working with the Province of New Brunswick, Aliant, Nortel, Dialogic and ClassCo, Telcordia will run a parallel demonstration site in the province of New Brunswick Canada. The province is looking at the system for an all hazard, all location solution for the entire province.

Telcordia has played a unique and critical role in the development of modern communications in the United States and has heavily influenced the global telecommunications infrastructure. This telecommunications infrastructure is the backbone of systems vital to emergency communications across the country—and around the world. For more than 75 years, Telcordia which was formally Bellcore/Bell Laboratories has been providing technical support and consulting services on issues affecting communications equipment and services resulting from fires, floods, earthquakes, explosions, chemical exposure, and loss of environmental controls. Telcordia will play an ongoing role in the deployment of customized solutions, providing integration and consulting to the many stakeholders including emergency managers and their equipment and software suppliers; telecommunications carriers and their suppliers; suppliers of consumer and business telephone devices; government entities; and related associations.

It is technologically feasible to delivery hazard information through a variety of existing and evolving wireless and wireline technologies as well as through TV broadcast, sirens and door to door notification. The question is not can we do it, but what combination of methods should we choose to obtain the most effective method for warning the public.

Telcordia Technologies has utilized its engineering leadership in telecommunications to develop an "All-Warning" emergency notification solution designed to optimize the public switched telecommunications network (PSTN) to deliver rapid notification of area s as specific as a single home. The advantage of the wireline telephone network is that it reaches 95+% of all locations, and provides the opportunity to rapidly reach one location, a specific list of locations in various areas, or all locations in a specific geographic area of any size or shape. Telcordia provided a "proof of concept" test in Deerfield Beach, Florida, in 1999 and is currently planning "trial" service in Fayetteville, Tennessee, and, New Brunswick, Canada, in October of 2000. Telcordia anticipates bringing the product to market in 2001 via the telephone companies in the United States and Canada. The system known, as "Community Notifications Solutions" is not just a weather warning system, it's an 'All Warning' system. A receiving device will be placed in every home and business in the country. Emergency notification will be controlled by the Emergency Management Authorities at the local, state and/or federal level with their choice of implementation. Control may be implemented:

• At the municipality or township level (police, fire, 911 dispatch desk, etc.)

• At the county level where it is applicable for those towns and small communities which may have a county wide emergency management system in place
• At the State level for State wide emergencies
• At the Federal level for national or multi-State emergencies, or
• ALL or any combination of the above

The Community Notification Solutions technology serves to enhance or supplement all technologies employed for emergency notification.

2) What are the tradeoffs among technology options?

3) What are the economic impediments, if any, to the use of any of the technologies that might be used to disseminate hazard warnings?

There are three major components to effective hazard warnings:

1. Content Generation

• What is the warning?
• Who needs to receive it?
• How long is it in effect?

1. Delivery of Content to Public Safety, Emergency Management Organization

• Notifies appropriate Public officials of impeding event
• Makes decision to deliver content to specific segment of general population
• Initiates delivery to public

1. Effective and rapid Delivery of the information to the general public

As with the introduction of any technology, there are economic considerations that must be faced - infrastructure costs, maintenance, administration, and evolution. The encouragement of public and private partnerships to deliver an effective solution will be needed. This could entail Public Safety Tax Credits, Insurance Rebates, Commercial Subsidies and Government Grants.

Currently, there are expenses associated with each of the different technologies that exist for public safety. For example, to place two new sirens within a small town (with small geographical layout of 2000 homes) is about $50K, to provide weather radios for the same number of homes (2000) is about$160,000. Telcordia has estimated that the CNS systems with a box in every home (2000) and a potential service charge from a local communication provider could be less than the cost of the two sirens.

Telcordia Technologies DOES NOT see any large economic impediments for the Community Notification Solutions. To the contrary, the delivery platform was purposely built to add to the existing PSTN infrastructure with a commercial aspect in mind to make the total service attractive to the communication service provider companies.

Telcordia™ Community Notification Solutions are ideally suited to public safety notification, public information delivery, subscription information services, and commercial messaging. Survey results indicate that people using the solutions are also more likely to subscribe to related services. Ex. Caller ID. As a result, the revenue generated from commercial uses may offset costs for public safety. Ex. Utility company, doctor appointment reminder, daily weather forecast. The notification devices also offer carriers additional cost saving opportunities related to service calls, providing them with the ability to evaluate service before rolling service trucks.

4) What are the legal impediments, if any, to the use of any of the technologies that might be used to disseminate hazard warnings?

The main legal impediment for both the public and private sectors is the potential liability associated with the three components of a warning system

• Liability of generating and maintaining a Hazards Data Base - Content
• Liability of Emergency Management/Public Safety for deciding who and when to notify - Decision
• Liability of the service provider/manufacture of the delivery mechanism - Delivery

These same issues are faced today by E9-1-1 call takers, Firemen, Police, National Guard and even NOAA. The development of standard Local, State, and Federal – Limits of Liability would be needed. This already exists in some states for E9-1-1 and would need to be expanded.

5) What legal measures, if any, should be taken to foster the delivery of hazard warnings?

Shared Data: An event has three common elements: Location, Message, Duration. The Federal government should take the lead on developing standards for the sharing of data between jurisdictions (town, county, state, and federal) and between technologies. The Federal government should also take the lead in developing databases for the sharing of this information, either through push or polling applications.

It should also be noted that Emergency Management, at all levels of government, are not in compliance with a "mandated" to provide "emergency notification" to the community-at-large in the event of an emergency or disaster due to the availability of supporting infrastructure, economic limitations or questions on liability.

6. What economic and technological policy measures, if any, should be taken to foster the dissemination of hazard warnings?

1) The government should lead the development of interoperability standards for the sharing of data between jurisdictions and technologies.

2) A "Tax Credit", Grant, or Universal Fund could be considered for the technology partners who will be providing time and material to implement a national strategy at the request of the various factions within the federal government. Items such as but not limited to:

• Standards Development
• Engineering Support

• Equipment Modifications & Upgrades
• Equipment Installations

• Procurement of New Technology and Devices
• Public Notification via Media
• Product Support at Local Levels

As this will be a "National Warning System" it will be necessary to create a plan to roll the technology out as a ubiquitous service countrywide. Although Telcordia has designed a low cost delivery system and device, a capital investment by all parties to launch the service will exist. A "Tax Credit", Grant or Universal Fund for those involved could help as an incentive to fast track the service for the nation as a whole.

Additional Information on Telcordia Community Notification Solutions

Work completed and underway by Telcordia Technologies:

• Proof of concept in Deerfield Beach, Florida. A sampling of 200 homes/businesses were used to test the device, software/hardware

• 97% acceptance. Test community engaged age groups from 21 years old to 86 years old.

• Participants stated that they had never felt so in touch with the community. Provided a sense of security

• 82% of the people said they would buy the service tomorrow for $1.50 - $3.00 per month

• Public and private participants include FEMA, Tennessee EMA, Lincoln County EMA, City of Fayetteville, BellSouth, Dialogic Communication Corporation (DCC), Lucent, ClassCo, Cybiotronics, and Bradshaw Consulting, CopperWeld, citizens of Fayetteville.

As a result of trial, standards will be released for the deployment of service

• Trial in Canada October 2000 to evaluate use of system for entire province

• Communication Service Providers

• US Government – (FCC, NARUC, DoC, FEMA, FBI, NASA, NSA, Departments of: Justice & Commerce, United States Chamber of Commerce, DoD - Weapons of Mass Destruction Inter-Agency Board), Canadian Federal Government, British Government via a private sector association

• Associations: NENA, NEMA, NFPA, APCO Disaster Recovery Journal - private sector

• Other organizations related to counterterrorism

• Hazardous material spill/ release/ storage
• Military CSEPP event
• Fire (forest, chemical, high density area)
• Tornado, hurricane, blizzard, severe thunder storm
• Criminal activity (riot, bomb threat, escaped convict)
• Flood, landslide, avalanche, mudslide
• Earthquake, volcanic eruption
• Dangerous animal (rabies, wild stray)
• Nuclear risk (power facility, weapon sites)
• Power Outage (during winter or extreme heat)
• Block Watch/ Block Parent (missing child)
• War

• School closings
• Megan’s Law notification
• Road closing or congestion
• Community meeting

Telcordia is committed to delivering valuable applications and services that meet your business needs. If you have any questions about this proposal, please contact: