Revising RBPS 13 for NTAS

I have been mentioning for the last couple of weeks now that ISCD needs to revise the Risk-Based Performance Standards Guidance document to reflect the change from Homeland Security Advisory System (HSAS) to the new National Terrorism Advisory System (NTAS) that was implemented earlier this week. Of course it is easy to complain about someone not doing something; it is more productive to actually suggest something so that is what I am going to do.

I’m going to do a minimalist revision of the RBPS 13 section of the Guidance document; keeping as much as possible the DHS-ISCD flavor of the document. I’ll explain the changes as I make them here in the blog and then I will post the revised version on my web site. Then, I’ll open the floor to a public discussion. We’ll do the same with the Metrics at the end of the section in a separate blog.

Cut and Paste

The first thing we will do is to use the cut and paste feature of the word processing program to replace ‘Homeland Security Advisory System’ with ‘National Terrorism Advisory System’. Next we will do the same with ‘HSAS’, replacing it with ‘NTAS’. Then we will replace references to ‘Color-coded Threat Level System’ with ‘National Terrorism Advisory System’. Then we go back and remove redundant references to ‘NTAS and ‘National Terrorism Advisory System’. We also removed the changes made in the name of the ASIS reference at the end of the section.

Explanation of NTAS

Next we would remove the section describing the out-dated ‘Color-coded Threat Level System’ and replace it with a description of the NTAS Alerts from the NTAS Public Guide.

Discussion of Sample Security Measures

We will change the description of the conditions that call for the additional security measures, replacing the ‘High Condition (Orange)’ description with one reflecting an ‘Elevated Threat Alert’. The second category; ‘Severe Condition (Red)’ description will be replaced with one for ‘Imminent Threat Alert’.

Length of Period of Elevated Threat Level

One of the major changes in moving from the HSAS to the NTAS systems is the elimination of open ended periods at elevated threat levels. The NTAS system includes a requirement for specific time limits that are included in the Alert when it is issued. While it is still possible to be at an elevated threat level for a lengthy period of time (probably only measured in weeks), it will remain at the specified level only for the specified time. The discussion under the section for the ‘Length of Period of Elevated Threat Level’ will be revised to reflect this change in philosophy.

References

Finally, we will change the URL for the DHS web site for the advisory system to reflect the new URL for the new NTAS system.

Minimal Revision

The revision described here is a minimal change to the RBPS 13 section of the Risk-Based Performance Standard Guidance document. The only things changed were those necessary to properly reflect the change in the DHS advisory system from the old color-coded system to the new system of National Terrorism Advisory System Alerts

It wasn’t a difficult re-write; it took less than two hours of work. Of course in the ISCD environment there would be multiple levels of approvals that would require at least a couple of additional re-writes. Then there would be the public publishing and comment period that would extend the time necessary to actually require facilities to implement the change.

One would like to think that the work on the RBPS 13 revision was started shortly after Secretary Napolitano signed off on the revised alert system. That would have allowed for the shortest amount of time where there would be discrepancies between the provisions of the advisory system and the requirements for the CFATS site security plan. Maybe this will allow ISCD to catch up.