Friday, May 21, 2010


Yesterday the Federal Communications Commission published their Final Rule for the establishment of the Emergency Response Interoperability Center (ERIC). According to the preamble to the rule “ERIC will be tasked with implementing national interoperability standards and developing technical and operational procedures for the 700 MHz public safety broadband wireless network” (75 FR 28207).

The rule establishes ERIC within the Public Safety and Homeland Security Bureau (PSHSB), but the details of the internal operation of ERIC were largely excluded from the final rule “because the adopted rules are rules of agency organization, procedure, or practice that do not substantially affect the rights or obligations of non-agency parties”. The rule does provide for the appointment of advisory bodies to advise ERIC. There is nothing in the rule that would specifically affect the chemical security community, but it does give me a chance to continue to plug for ensuring that security programs at high-risk chemical facilities can and do routinely communicate with local law enforcement.

The development of the use of the 700 MHz for broadband wireless communications for the public safety community provides an excellent opportunity to tie both the security teams and emergency response teams at high-risk chemical facilities into the communications capabilities of local law enforcement and first response community. In most cases where there is a serious incident, either accidental or as the result of an attack, at these facilities the on-site personnel will already be attempting to deal with the situation by the time that local response arrives on scene.

As the local incident commander takes control of the scene, gaining up-to-date information from the facility response teams will be critical in planning and executing the off-site response. This informational exchange can only be enhanced if the on-site personnel have interoperable communications and have trained with the local responders.

 Of particular importance in this interoperable communications will be the provisions for high-speed data communications to share information like live video from on-site surveillance cameras. Additionally a wide range of process sensors could provide invaluable information about the physical conditions of critical storage tanks and process equipment. Facilities with a network of chemical detectors to identify and track leaks would find that the local responders would greatly appreciate that information.

So, I’m taking this opportunity to stand on my soap box to urge the FCC, through ERIC, to take into consideration the high-speed data communications requirements between high-risk chemical facilities (and obviously other critical infrastructure and key resource facilities) and local first responders and law enforcement when they plan. Unfortunately the FCC did not make provisions for public comments in the publication of this rule, so I just stand here on my soap box. Perhaps Congress could include provisions in any CFATS reauthorization (if and when) mandating the establishment of such communications channels.

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