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Subject: Public Comment


Comment from: daylward@comcare.org

							November 20, 2003


Comments of the ComCARE Alliance on the OASIS Draft Common Alerting Protocol (CAP) Standard	


The ComCARE Alliance is a broad-based, not-for-profit national coalition of more than 90 organizations representing nurses, physicians, emergency medical technicians, 9-1-1 directors, emergency managers, transportation officials, wireless, technology and transportation companies, public safety and health officials, law enforcement, automotive companies, consumer organizations, telematics suppliers, safety groups, and others.

"ComCARE" stands for Communications for Coordinated Assistance and Response to Emergencies.  Our goal is to promote an integrated, coordinated approach to emergency communications.  We are working to encourage the development and deployment of life saving communications and information technologies that will enhance America's emergency response capabilities. This will save thousands of lives each year, substantially reduce the severity and length of injuries, assist law enforcement and transportation, and enhance homeland security.  Perhaps most importantly, we encourage and facilitate cooperation across professional, jurisdictional and geographic lines, seeking to break down the walls that separate these agencies and professions, and thus limit
their effectiveness. 

We compliment the CAP Working Group and OASIS for this important draft standard.  We know how much work as gone into it.  We are proud that its initial field trial uses were in ComCARE-supported drills in Virginia earlier this year (including a pneumonic plague drill in October).  And we are most proud that the primary author and facilitator of the CAP standard, Art Botterell, was ComCARE's Associate Director until very recently.  Demonstrating his deep commitment to the public interest, he developed the first versions of this standard, with no compensation from anyone, before he came to work for ComCARE last year.  Thus it should not be surprising that we have very minor comments on the draft.  They all revolve around one area: addressing messages. 

We have spent a great deal of time over the last 3 years developing the concept and now a prototype of a passive GIS-based registry of emergency agencies.  It will be a shared, non-profit resource, managed by a public/private board.  With a published interface it will enable multiple competitors and applications.  Thanks to a recently-received grant from the Department of Justice, we are commencing an intensive effort to develop a production version of this registry (the Emergency Providers Access Directory, or EPAD), and put it into use.  

EPAD allows emergency response agencies (and private organizations such as a media outlet, utility, etc) to register themselves, their contact information (telephone, IP address(es)), their organizational category (law enforcement, transportation, 9-1-1, media), their informational interests (e.g. weather events, car crashes, crimes, bio-terrorism alerts), and to put two geographical boundaries ("polygons") on each of those incident types: what is the agency’s jurisdiction, and a broader area for which they would like to receive notices.  This will allow a user of a CAP product to select not only an area in which to notify parties, but to sub-select by the type of organization, and/or by the specific type of informational interest.  The latter is addressed generally by the current "cap: category" section, but it is at a higher level than that in which we have found interest.

We recognize that the CAP standard originated from the field of public warning ("broadcasting"), not inter-agency or inter-organizational communications ("narrowcasting").  However, our field experience with CAP in our Virginia drills has confirmed that it has a great additional value in being used for that latter purpose.  This additional use requires that the initiator of a message at least have the option of directing a CAP message more narrowly than the current draft standard
would seem to allow, e.g. “to all police agencies in this polygon”, or “to all government agencies signed up for homeland security alerts with jurisdiction over this lat/long”.   Our suggested changes would allow the new CAP standard to benefit fully from EPAD's capacities, but also from other forms of organizations reflecting and/or registering their affiliations and informational interests.  The following are our minor suggestions which we respectfully submit for your consideration.

Section 2.2 Requirements for Design

	We request that you add new lines 7e and 7f, after line 219:

e.	Target category(ies) of agency or organization
f.	Target category(ies) of event and/or information interest (i.e. based on the event types for which the standard already provides, or subsets of them). 

Section 3.1 Document Object Model

	It appears from the final box in the chain that the only targeting/addressing mechanisms for a CAP message are geographic and a limited number of summary event types.  These are critical.  We respectfully suggest that two further targeting/addressing selections be allowed: agency or organizational type (e.g. law enforcement, school), and specific informational interest expressed by recipients. These targeting mechanisms should be assigned at the alert level to allow registries/subscription services to most effectively manage distribution requirements.

Section 3.2 Data Dictionary

	To carry out our suggestions, we suggest that two further optional fields be included:

(a)	add "alert:eventType" to provide subscribable event types.

(b)	add "alert:targetOrganizationType” to allow more effective direction of messages from a sender's viewpoint. 

Both fields should allow multiple values to be used in a way analogous to key word searching by a search engine.

Longer Term Solution for Emergency Messages

EPAD can be an effective subscription registry for all kinds of emergency messaging defined by OASIS standards. We would suggest that the kinds of information provided by subscribers and useful to message initiators for routing purposes would best be moved into a general purpose Emergency Message Envelope.  For our purposes this would include both event type and target organization type as defined above.  It would also include location or "area" as currently defined in CAP.  This abstraction of needed distribution management information into a general purpose wrapper would make the development of efficient distribution mechanisms possible for all kinds of messages as they are developed by the OASIS Emergency Management Technical Committee and its member companies.

				Thank you for your consideration. 



				David K. Aylward
				Director


cc:  ComCARE STIC Committee





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