Sunday, June 23, 2013

Comments on Proposed Revisions to NIPP – 6-22-13

This is the first in a series of blog posts about the public comments posted to the DHS proposed revisions to the National Infrastructure Protection Plan (NIPP).

We are now a little over a week into the one month comment period and four comments, all from individuals, have been posted to the Federal eRulemaking Portal for this docket. None of them is particularly responsive to the proposed revisions to the NIPP. We do have suggestions for:

• Building sea water canals into the interior of Western Africa to help prevent hurricanes along the East Coast and Gulf Coast of the United States;
• Providing more public availability of severe weather warnings;
• Placing educational institutions in their own Critical Infrastructure Sector (okay this comes close to what the NIPP is all about); and
• Making it a federal criminal offense to undertake a variety of criminal actions on, at or against Critical Infrastructure facilities (it takes Congress to enact criminal statutes).

The main problem with these suggestions is that they actually propose specific actions to be taken by the Federal Government. Anyone that has managed to stay awake long enough to read the current NIPP (and I am not one of that very limited number) would understand that this is a bureaucratic statement of general policy that is flexible enough to cover just about any action the Federal Government takes or doesn’t take with regards to Homeland Security.

I suspect that in the coming weeks we will see comments from a number of NGOs and contractors suggesting additions that would favor their pet projects. That is what we saw during the comment period for the last update in 2008.

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