FR 2021-01144

The Federal Emergency Management Agency (FEMA) has issued a notice inviting public comments on a proposed revision to the Emergency Notification System (ENS). This initiative is part of FEMA's ongoing efforts to enhance efficiency and reduce paperwork. As a key component of FEMA's preparedness strategy, the ENS is essential for sending timely notifications and alerts to Department of Homeland Security (DHS) employees, contractors, and emergency personnel during crises. Comments on this proposal can be submitted by March 22, 2021, through the regulations.gov website.

General Summary

The document is essentially a request for public input on potential changes to a previously approved data collection tool, the ENS. This system plays a significant role in DHS's Continuity of Operations Planning (COOP) by ensuring that crucial functions continue unabated during emergencies. FEMA's intention with this notice is to refine the notification tool, which is critical for disseminating information and activating response teams efficiently.

Significant Issues and Concerns

There are several notable issues within the document that may raise concerns:

• Unclear Cost Details: The document estimates that the total annual cost to the federal government will be $214,651, but it fails to provide detailed information on how this sum is allocated. This lack of transparency can cause apprehension about the possibility of wasteful spending or misallocation of resources.

• Unspecified Calculative Methods: The calculation methods for both the estimated total annual respondent cost ($6,247) and the government's annual cost lack clarity. This absence of clear methodological explanation may undermine confidence in the accuracy of these figures.

• Ambiguity in Data Collection Necessity: There is no detailed explanation of how the agency determines the necessity of this data collection for its operations, which creates uncertainty. The criteria or processes for evaluating this necessity would need elucidation to ensure public understanding and confidence.

• Lack of Specificity in Proposed Revisions: The notice does not specify what particular changes or revisions are being considered, leaving the public without a clear understanding of how the modifications might affect them.

• Opaque Details on New Form: A new form for data collection is mentioned, but details regarding its content or purpose are not provided, leading to potential misunderstanding.

Broad Public Impact

The public may experience direct and indirect effects from any changes to the ENS. On a broad level, enhancing the efficiency of emergency notifications could ensure better-prepared communities during crises. However, without clarity on the costs and benefits of these changes, there may be skepticism about the effectiveness of the proposed revisions.

Impact on Specific Stakeholders

Different groups are likely to be impacted in varied ways:

• State, Local, and Tribal Governments: These entities may benefit from more reliable and timely emergency notifications, supporting their roles in safeguarding communities. However, lack of transparency around costs and processes might lead to resource allocation concerns.

• Federal Government: The estimated costs imply a financial commitment that, if not transparently justified, could attract scrutiny from oversight bodies focused on government spending efficiency.

• Mobile Operation Centers and Regional Responders: These operational groups depend on the ENS for decisive action during emergencies. Any improvements to the system could enhance their effectiveness. Conversely, they might face challenges if new procedures or tools are not clearly communicated.

FEMA's proposal represents a crucial component of national security and public safety strategies. Nevertheless, to ensure stakeholder support and public trust, it must address the outlined issues with transparent, detailed, and specific information regarding the proposed revisions and their implications.

The document discusses the financial implications surrounding the Federal Emergency Management Agency's (FEMA) Emergency Notification System (ENS) as part of an information collection activity. This initiative, as detailed, includes estimates and costs that bear scrutiny.

Estimated Total Annual Respondent Cost

The document identifies the Estimated Total Annual Respondent Cost as $6,247. This figure represents the expenses that respondents, which include state, local, or tribal governments as well as the federal government, are expected to incur annually. However, there is a lack of detailed information on how this estimation was calculated. Without specific details, respondents may question the accuracy of this figure and whether it comprehensively reflects the real costs associated with their participation in data collection activities.

Operation and Maintenance Costs

Interestingly, the Estimated Respondents' Operation and Maintenance Costs and Estimated Respondents' Capital and Start-Up Costs are both stated to be $0. This suggests that there are no expected additional expenses for maintaining or initiating the ENS beyond the primary respondent costs. This zero cost estimation simplifies the financial burden on respondents but simultaneously raises questions. It is essential to understand if this reflects a genuine lack of maintenance or start-up costs, or if these figures simply have not been detailed adequately. Clear articulation is needed to avoid misconceptions about hidden costs or expenses that might arise.

Total Annual Cost to the Federal Government

Furthermore, the document outlines an Estimated Total Annual Cost to the Federal Government of $214,651. This figure presumably covers program-related expenses incurred by FEMA in operating the ENS. However, no detailed breakdown of this cost is provided, which could lead to concerns about potential inefficiencies or wasteful spending. Understanding how this amount is distributed among various operational needs, such as technology, personnel, or administrative expenses, would provide valuable insights and reassure stakeholders that funds are being used effectively.

Relation to Identified Issues

The issues identified, particularly regarding the transparency and methodologies in calculating these financial figures, highlight the need for more explicit financial documentation. Detailed financial information would enable stakeholders to better understand the necessity and utility of the data collection process, potentially improving the credibility of the financial allocations. The lack of clarity around these costs poses a risk of misunderstanding and could hinder the ability of individuals or entities to provide informed feedback on the proposed collection revision.

In summary, while the document presents financial allocations related to the ENS, the absence of a detailed breakdown offers room for misinterpretation and concern. Clear, transparent financial reporting would be helpful in addressing these issues and assuring all participants of the efficacy and necessity of the initiative.