Comment submitted by M. A. Whitney

02/01/2006 Subject: DHS-2005-0051 SAFECOM Interoperability Baseline Survey Comments ? Whitney Index: ? Summary ? Proposed Addition ? Discussion ? Consequence Management in a Map-Driven Enterprise ? Fire Chief ? 07/2004 ? 2005 and 2006 DHS State and Local Grant Guidance ? Hurricane Andrew GIS Coordinator?s After-Action - 10/1992 ? Hurricane Katrina Lessons Learned ? MS State EOC GIS Coordinator - 09/13/2005 (Brooks) ? KATRINA ? Lessons Learned (again) ? KATRINA (NIMS) ? Lessons Learned (?a critical failing?) ? Brooks - After Katrina and Rita - 12/19/2005 ? The United States Marine Corps Chemical Biological Incident Response Force ? In Conclusion ? FEMA ? NewsHour Interview Lehrer/Rhode ? Katrina Day Two (excerpt) ? Summary Having reviewed the proposed SAFECOM Interoperability Baseline Survey, I have come to the well-supported conclusion that it will fail to attain it?s stated purpose of establishing an interoperability baseline for the USA emergency services sector as it does not address a universal spatial reference system, and in particular, the consensus standard established 12/2001 for the USA by the Federal Geographic Data Committee (FGDC), the US National Grid (NAD-83/WGS84). In order to gauge a true ?interoperability baseline? on an ongoing basis, this critical failing to measure implementation of such a fundamental requirement, USNG, especially in terms of ?a common doctrine for how multiple jurisdictions should interact and respond to a single incident, or to numerous simultaneous incidents which span multiple jurisdictions?, will need to be addressed in the SAFECOM survey, as the lack of implementation remains ?a critical deficiency in U.S. consequence management.? ? Proposed Addition ? Add Questions ?Communications and Communications Equipment? Heading Map coordinate system. a. Do you have a map coordinate system you would use to help direct your emergency response partners to specific locations? ? Yes ? No ? Don?t know b. If yes, what system do you use? ? Based on one of the three versions of longitude/latitude ? Local system ? Map Grid/Street Address/Box Alarm Number ? Based on US National Grid (USNG)/Military Grid Reference System (MGRS) ? State Plane Coordinate System ? Other (specify) _______________________________ ? Discussion ? Consequence Management in a Map-Driven Enterprise In terms of ?interoperability? of plans, operations, communications, geospatial tools -paper and digital, used for consequence management of incidents catastrophic, large, and small, a common map grid (USNG) used by all response assets is not just preferred, but required if performance of response, recovery, mitigation, preparedness elements of the emergency services lifecycle are to function seamlessly (integrated/interoperable). In the first ever US Fire Service Needs Assessment (FA-240 USFA/NFPA) submitted to Congress 12/2002, the term ?interoperability? is only used to ?address the ability of fire departments to access a map coordinate system with sufficient standardization of format to provide effective functionality in directing the movements of emergency response partners.? The responses of more than 8,300 fire departments were analyzed and resulting information led to the following conclusions: ?Table 44 indicates that nearly half of all fire departments have no map coordinate system. This is a problem particularly for smaller communities, up to 99,999 population. About one-seventh of communities with at least 500,000 population have no map coordinate system. Table 45 indicates that the vast majority of departments with a map coordinate system have only a local system, which means the system they have is unlikely to be usable with global positioning systems (GPS) or familiar to, or easily used by, non- local emergency response partners, such as Urban Search and Rescue Teams, the National Guard, and state or national response forces. Moreover, interoperability of spatial-based information systems, equipment, and procedures will likely be rendered impossible beyond the local community under these circumstances. This reliance almost exclusively on local systems exists across-the-board, in all sizes of communities.? (bold added) ? Fire Chief ? 07/2004 (http://firechief.com/news/national-grid-usng8376/index.html) ?Interoperability, in addition to sharing voice communications, means that everyone ? state, local and federal emergency response forces ? can share maps and location information in emergencies. It?s critical that lifesaving people and resources get to the exact location where they?re needed -- even if street signs and familiar landmarks are destroyed in a disaster or if the emergency is in a remote area?USNG?something envisioned by the Department of Homeland Security?s National Incident Management System and National Response Plan? It boils down to interoperable response. Fire departments and other emergency responders should work from a USNG-based mapping\location system because USNG works particularly well in cross-jurisdictional emergency operations?.? ? 2005 and 2006 DHS State and Local Grant Guidance "The following describes those federally maintained, endorsed or adopted initiatives that grantees are strongly recommended to review: National Spatial Data Infrastructure (NSDI)...; Geospatial One-Stop...; United States National Grid (http://www.fgdc.gov/standards/status/usng.html) The objective of this U.S. National Grid standard is to create a more interoperable environment for developing location-based services within the United States and to increase the interoperability of location services appliances with printed map products by establishing a nationally consistent grid reference system as the preferred grid for NSDI applications. The U.S. National Grid is based on universally- defined coordinate and grid systems and can, therefore, be easily extended for use world-wide as a universal grid reference system. There are a number of coordinate reference systems that can be used either in location service appliances or on printed maps for the purpose of establishing a location. Within automated location service appliances, the conversion of coordinates based on one well-defined reference system to coordinates based on another can be both automatic and transparent to the user. These devices can support multiple coordinate reference systems with little difficulty. However, it is not easy for humans to work in multiple reference systems and humans cannot convert between systems without the aid of location service appliances, calculators, or conversion tables (FGDC-STD-011-2001);"?. ? Hurricane Andrew GIS Coordinator?s After-Action - 10/1992 ?General information type maps with no UTM grid, in a disaster environment without street signs, few recognizable landmarks with no response specific data were very nearly useless? An actual accounting of all the requests for emergency assistance that went without, or the delay encountered by the countless movements of personnel, food, and equipment will likely never accurately be tallied?. DISCUSSION: The Emergency Support Function #5, Information and Planning Annex of the Federal Response Plan while containing quite allot of goobly gauck about collecting, processing and disseminating information through proper channels etc..., mentions the word map(s) 5 times. The annexes perceived, and minor focus on mapping is for the internal informational needs of Disaster Field Office "leadership" elements and does not address the needs of the actual responder trying to get a difficult job done under arduous conditions. Not to mention the who, why, what, when, and where of obtaining mapping products that will graphically present the many aspects of a disaster response to all who need the information with UTM grid coordinates for the military, and hopefully someday other users of the information.? (Whitney - Hurricane Andrew GIS Coordinator?s after-action report to the Center for Army Lessons Learned, 10/06/1992) USNG-NAD83/WGS84 is based upon UTM and MGRS. ? Hurricane Katrina Lessons Learned ? MS State EOC GIS Coordinator - 09/13/2005 (Brooks) ??A. Two fundamental maps sets are created. One for decision makers among all participating agencies and one for responders from all participating agencies?. Data availability is critical? The following were data shortfalls during Katrina A. Lack of a common reference system?.? (Talbot J. Brooks, Director, Center for Interdisciplinary Geospatial Information Technologies Delta State University) Note: Dr. Brooks, until a month or two after Katrina, had never heard of the USNG- NAD83 standard. We've got to do a much better job getting the word out, NIMS, SAFECOM? before the next hurricane season. ? KATRINA ? Lessons Learned (again) (http://www.usfa.fema.gov/subjects/emr-isac/infograms/ig2005/igoct2005.shtm) 10/20/2005 ?United States National Grid Two hurricanes in the Gulf Coast last month exposed some new lessons for the Emergency Services Sector. The experience also re-taught some old ones as well. A significant lesson repeated for "Katrina" and "Rita" responders was the need for quality maps containing a common or universal grid reference system that also works well with Global Positioning Systems (GPS). Reports from the impacted areas indicated that many available printed maps lacked essential details to get emergency personnel where needed, particularly where street signs, key landmarks, and other major terrain features no longer existed. The EMR-ISAC supports the United States National Grid (USNG-NAD83 ) as the solution to this infrastructure and interoperability problem. USNG was adopted as the National Reference (Location) Standard in 2001 by the Federal Geographic Data Committee (FGDC) to enhance homeland security and public safety. The standard is based on universally defined coordinate and grid systems to create a more favorable environment for location-focused services and the interoperability of those services. This (USNG) location reference system provides a common language that enables all users to rapidly share maps and location information in any emergency or contingency. USNG lends itself to maps much better than any of the three versions of longitude and latitude, especially in large scale or multi- jurisdictional operations. The U.S. Fire Administration Interoperability Advisory Team recommends the fire service begin using the USNG as a universal location reference system so that everyone is using the same grid coordinates. (http://firechief.com/news/national- grid-usng8376/) Because of its probable benefits for critical infrastructure protection, the EMR-ISAC advocates USNG acceptance and application by all components of the Emergency Services Sector for incident responses on a local, regional or national level. See the FGDC website at www.fgdc.gov/usng/ for more information. Also note that older GPS equipment should be set to the interoperable Military Grid Reference System (MGRS-WGS84).? ? KATRINA (NIMS) ? Lessons Learned (?a critical failing?) A Project Responder Report: Technology Opportunities for Implementing the National Incident Management System (NIMS) Of October 2005, by Hicks and Associates, Inc., for The Memorial Institute for the Prevention of Terrorism and the United States Department of Homeland Security. (p.17) ?Doctrine for Response in a Multi-Event, Multi-Jurisdiction Environment Across the emergency response community there is no common doctrine for how multiple jurisdictions should interact and respond to a single incident, or to numerous simultaneous incidents which span multiple jurisdictions. This is a critical failing. NIMS was intended to address issues of cooperation and coordination, but must now be followed-up by more specific operating guidelines and facilitating structures. Lack of doctrine is not inherently a technological issue, but technology might offer the beginnings of a solution. Doctrine can emerge from training, exercises, and simulations, and thus it is possible that training technology which simulates a complex multijurisdictional environment may help in doctrine development. The current lack of comprehensive doctrine is exacerbated by the lack of common terminology. While NIMS aims, in part, to establish common terminology across organizational functions, resource descriptions, and incident facilities, there are still differences across disciplines and regions which must be overcome. Emergency responders and managers stress that problems caused by these differences can inhibit the success of both pre-incident planning and field operations?.? (p. 31) ?Problems/Issues/Gaps: Responders? lack ability to share information between the MAC (Multi-Agency Coordination Entities) and area command posts is partially due to weak communications and interoperability standards. This is evidenced by situations where MAC and area commands may both be utilizing digital maps, but with different indexing standards. The result may be an inability to easily exchange map coordinates?.? ? Brooks - After Katrina and Rita - 12/19/2005 ?After experiences with both Katrina and Rita, I cannot underscore (enough) the importance for the move to the National Grid. Several reasons stand out: 1. Military assets are consistently used during disasters. The US National Grid system is very similar to MGRS and I think it would be easier to train soldiers in its use than in any particular state's system. 2. The ability to make sense out of distances based singly on provided coordinates. Most everyone knows roughly how far a meter is, for a field commander to simply look at a set of coordinates and intrinsically know how far apart they are is an advantage when pushed for fast action potentially without a map in hand. 3. The National Grid is readily available on most all GPS-based devices now whereas in places like MS, which uses Mississippi Standard Transverse Mercator (MSTM, or UTM 15.5 if you will), it might be a bit tougher on lower end units. 4. It provides ready-made search and rescue grids in the event of disaster. 5. Flexibility of accuracy. If you're looking for a house, report the coordinate in 6 or 8 digits and it will still make sense. Searching for a gas valve that must be shut off, report in 10 digits. When working with lat/long, people did not have a conceptual understanding of how big a "second" was and why it was needed when making the translation from street address to lat/long. 6. Prevents the confusion inherent with lat/long. I found that there was much confusion when folks would interchangeably use decimal degrees and d.m.s with decimal formats. Best ways to promulgate: 1. Get it into education - teach our students what it is and why it is important. UCGIS had a blind eye to it last time I checked (I'm reading the latest version of their recommended curriculum now, so it may have changed). 2. Get it into the software - write a free conversion routine that can plug into ArcGIS, Intergraph, etc... without any fuss. 3. Educate through professional societies such as AAG, GITA, URISA, NSGIC, MAPS, ASPRS, etc.. 4. Legislate it in as a requirement for any and all future DHS funding related to disaster preparedness. This approach worked with the ICS, it can work here too. I'm relatively new to the system myself, but became a firm believer after Katrina. It likely would have helped us to save more lives.? (Talbot J. Brooks, Director, Center for Interdisciplinary Geospatial Information Technologies Delta State University) ? The United States Marine Corps Chemical Biological Incident Response Force (Excerpts from 06/2005 RRL-240: since Katrina co-sponsored by Army, Navy, Marines, Air Force, NORTHCOM, SOUTHCOM, Office of Secretary of Defense, and the US Geological Survey) ?(U) Policy on use of Grid Coordinates for Homeland Security Requirement ID: 240 Functional Description of Requirement: (U) Request that NGA engage with appropriate U.S. civil authorities to facilitate the implementation of grid coordinates in Homeland Security operations. (U) To minimize operational friction during military support to civil authorities, USMC Chemical Biological Incident Response Force (CBIRF) based at Indian Head, MD requires the ability to use and exchange standardized map coordinates. The lack of a similar, standardized procedure by state, local, and many Federal Agencies is a critical deficiency in U.S. consequence management. Performance Characteristics: (U) Standardized map coordinates must be equivalent to Military Grid Reference System (MGRS) when referenced to North American Datum 1983 (NAD 83) or World Geodetic System 1984 (WGS 84), U.S. National Grid. Current Capability: (U) The United States National Grid (USNG) is the U.S. civil standard grid reference system, but is not used in operational activities for Homeland Security. Certain agencies use their own atlas grid, which are incompatible with DOD doctrine, training, maps, C2 systems, and GPS receivers. (U) While street addresses are important, they have innate operational and geospatial shortcomings and do not enable the use of GPS. In some scenarios, street-addressing infrastructure will be destroyed and we must plan accordingly. (U) When coordinates are used, it is often various forms of latitude and longitude. These do not support operational requirements and are not compatible with maps and training standards. Justification: (U) To improve support of interoperability, command and control (C2), in the exchange and reporting of geospatial information in Homeland Security operations. (U) The operational use of many different coordinate systems causes significant Impact if not Implemented: (U) CBIRF?s ability to respond to threats within the United States will continue to be severely hindered. There will be continued friction in Homeland Security operations in describing locations unambiguously. Customer Design Constraints: (U) Must be a standards based solution. The United States National Grid (USNG) is the U.S. civil standard grid reference system and presentation format for large-scale mapping, per Federal Geographic Data Committee (FGDC) standard FGDC-STD-011-2001. The USNG is functionally equivalent to Military Grid Reference System (MGRS). Recommended Solution: (U) That NGA engage with appropriate U.S. civil authorities to facilitate implementation of grid coordinates in Homeland Security operations. The intent of this requirement is not to replace street addresses as used by some agencies, but to supplement them with coordinates for civil response operations. Customer Comments: (U) This requirement strongly supports the need for NGA to engage with appropriate US civil authorities and extend to them the knowledge and benefit of DoD operational experience in the use of grid coordinates. The essential need for a single, standard coordinate system - as a communications medium (a language of location) is a new concept in the US civil community. Having a single grid reference system reduces training requirements and ensures frictionless exchange of location information between all committed forces and agencies. Based on hard earned experience in combat, all US ground forces are trained in the use of a single system - MGRS (equivalent to FGDC?s USNG) for large-scale mapping applications. All large-scale hardcopy maps (>1:1,000,000-scale), Global Positioning System (GPS) receivers, and digital systems are designed with a single, standard grid - MGRS. This ensures interoperability and frictionless exchange of positioning information between people as well as machines. ?? ? In Conclusion ?Interoperability? without a universal map reference system is impossible. Much else regarding USNG has been written by many other individuals, agencies, and this current White House ("One of the three most important immediate steps that the Government could take to improve homeland security." 12/2001). GIS vendors have created no-cost solutions to their products?, we have multiple lessons learned, still, these years since USNG was adopted our PSAPs, 911 dispatch, fire, police and others across the nation are not using a single reference system for geoaddressing to supplement street address. FEMA has even recently created a USNG centric ?GPS for Disaster Response Operations? training course, but what about the rest of the enterprise within FEMA, DHS, State and Local?.? So much needs to be done. How about their equipment, training, communications protocols? Interoperability? System? Unified command? This is no way to plan, prepare, train, and conduct disaster response/consequence management operations. We need to solve for the ?train wreck? that was Katrina search and rescue coordination and more. A universal map reference is the starting point, not an after-thought, as was pointed out by former FEMA Director James Lee Witt in his 02/02 USNG White Paper on ComCARE (http://www.comcare.org/uploads/USNG.pdf): ?The reward for using the USNG will be large. The cost of implementation is small and the risk low. It is an IT requirement for our Nation as we enter a new age of increasingly available spatial information for responders, planners, and the public. The requirement becomes more urgent as large dollar resources and effort are directed towards homeland security. Standards such as the USNG are best served early before the main course.? The NIMS-NIC will be considering USNG again the middle of this month (02/15/2006). Much of this information has been presented to SAFECOM in the past as well. If, the next time we face catastrophe/consequence management and on the second day of the disaster a NewsHour with Jim Lehrer interview with the ?deputy director of FEMA? (or other DHS management) goes as the one for Katrina day two did (excerpt below), ??something that we're working on right now with both the cities and the states as we go through this??, with whom will we place the blame? Is after a disaster strikes the time to attempt get all GPS/GIS/protocols/voice commo/data/plans? all set to the same reference? (Katrina, it never did happen.) Interoperability goes well beyond just having bandwidth and a working radio, it includes what is communicated and how. Adding USNG content to your baseline survey is one of many things SAFECOM could be doing regarding USNG implementation. ? FEMA Letter (FEMA GIS Working Group/Buckley) to the Federal Geographic Data Committee 06/2001 while USNG was in public comment period: "the FEMA program offices anticipate that the use of this system (USNG-NAD83) for identifying locations among emergency management personnel and agencies will help save lives, reduce the costs of disaster, and enhance preparedness, response, recovery, and mitigation efforts. Particularly valuable is its compatibility with the system used by the National Guard and others, the Military Grid Reference System (MGRS)." ? NewsHour Interview Lehrer/Rhode ? Katrina Day Two (excerpt) ??PATRICK RHODE: We are looking at massive amounts of commodities, disaster assistance teams, we're looking at urban search and rescue teams, all of which were pre-deployed ahead of this pending cat. 5 hurricane when it was pending. Now that we've seen landfall and now that we're getting a better idea of what we're seeing on the ground, we're looking at major operations whereby response elements are going to be utilized here in the next of couple days. We're looking at some of the largest search and rescue types of responses that we've seen in this country in quite some time. JIM LEHRER: There are still people trapped and unaccounted for, is that correct? PATRICK RHODE: We believe that that is correct. Unfortunately it's going to be a couple of days of going through and making these very, very difficult assessments in the most damaged areas before we can truly know what we're looking at. JIM LEHRER: Is there a system for doing that? Have you all worked out a grid system of some kind for checking out every place? PATRICK RHODE: That's something that we're working on right now with both the cities and the states as we go through this. We're really relying upon a combination of their intelligence and also our intelligence....? ? Thank you for the opportunity to comment on subject survey. Much more information regarding USNG is on http://www.fgdc.gov/usng/index.html Mark Mark A. Whitney PO Box 247 Emmitsburg, MD 21727 USNG: 18SUJ00449732