National Earthquake Hazards Reduction Program

Development of the 2009–2013 Strategic Plan General Comments

General Comments on the 2008–2012 Draft Strategic Plan (17)

• Comment: The report contains no mention of the severe cut to the USGS proposed by the Bush Administration for the FY2009 budget. How will NEHRP deal with such a cut? I see no contingency plan, nor any evidence of public response.
  
  [T]he plans outlined in the report don't mean much if not accompanied by the resources to accomplish the goals.
• Comment: The Strategic Plan presents a clear road map for the earthquake engineering community and the public at large. The authors are to be congratulated.
• Comment: NEHRP does recognize the existence of other natural hazards. Should text be added to discuss outreach to design professionals tasked with reducing the impact of other hazards. What lessons can NEHRP learn from other natural disasters in recent times?
• Comment: In reviewing the NEHRP Strategic Plan for the National Earthquake Hazards Reduction Program, I believe the best way to accomplish the programs' Mission Statement is as follows:
  
  Unless another source of funding can be identified, I believe the State of Alabama can and should use mitigation funds to pay for the planning and implementation of a public information campaign designed to:
  
  
  • Communicate the dangers of Earthquakes (risks and vulnerabilities) to the citizens that live in fault areas
  • Educate the population that special design/build techniques should be used in earthquake fault areas
  • Require communities in earthquake fault areas to adopt earthquake hazard mitigation plans, practices and policies
    
    
  Page 39 somewhat addresses these suggestions under Facilitate Improved Earthquake Mitigation at State and Local Levels. I believe the overall Strategic Plan is good and hopefully the NEHRP will provide some funding to the States that are potentially impacted by earthquake faults to impl[e]ment the plan.
• Comment: One big issue we somehow need to address is that "NSF has made a significant investment in the NEES test facilities, but now the funds available to use these same facilities is woefully short."
  
  I am currently a NEES Board member, and it is quite frustrating to observe this problem close up.
• Comment: A paragraph on knowledge transfer to and from other hazards might be appropriate.
  
  Suggestion: For example, what went wrong in Katrina and what do we do to ensure that it doesn't happen again?
• Comment: Would some timelines be useful?
  
  The Plan is for 5 years, but there is no chance in hades that we can accomplish all of the activities listed in the Plan in this period.
  
  Suggestion: If we could, would the end of NEHRP be in 2012? Perhaps some discussion on this matter would be useful, in the front of the document.
• Comment: EERI is pleased to have an opportunity to review and comment on the Draft Strategic Plan for the National Earthquake Hazards Reduction Program Fiscal Years 2008-2012.
  
  On behalf of the members of EERI, we would like to recognize and congratulate the Interagency Coordinating Committee, for this very thoughtful and comprehensive effort. We are impressed at its integration, the way in which the Plan brings the four primary NEHRP agencies together to address common goals and objectives collaboratively. We applaud the agencies for agreeing to "unified program planning with coordinated budget preparation." The organization of the Plan is clear, with just three overarching goals, a limited number of specific objectives and sound strategies linked to achieving these goals and objectives. The Plan does a fine job of drawing on the strengths and capabilities of each of the agencies to address the significant seismic challenges that face our nation.
  
  EERI fully supports the three goals, fourteen objectives and nine cross cutting strategies that have been identified to achieve the vision and mission of the NEHRP program. In particular we have emphasized below several areas of particular interest to EERI and our members. While we endorse this Strategic Plan, its goals, objectives, and strategies, we are fully cognizant that even the most well designed Plan will be limited in its effectiveness by the level of funding authorized and appropriated by Congress.
  
  In Goal A, improving understanding of earthquake processes and impacts, we recognize the importance of fully implementing the Advanced National Seismic System (ANSS) and the basic data on ground and building response that are so important to hazard assessment, building design, warning, and emergency response. We are pleased to see this strategic priority given top billing in this Plan.
  
  We are also pleased to see that Goal A and its objectives do not focus only on the need to improve basic understanding of earthquake phenomena, but are also sensitive to the need to improve understanding of earthquake effects on the built environment, as well as "understanding of the social, psychological, and economic factors that are linked to implementing risk reduction and mitigation strategies in the public and private sectors." Under separate cover, we are transmitting a copy of an EERI report, Earthquake Risk Reduction: Addressing the Unmet Challenges—The Need for an Interdisciplinary Research Approach, An EERI White Paper, January 2008, Oakland, CA, which supports this goal and concurs with the need to address such complex societal challenges from an interdisciplinary perspective.
  
  EERI is pleased that the Plan recognizes the current and potential contributions of Performance-Based Seismic Design (PBSD) as a strategic priority, in line with Public Law 108-360 to support the development of PBSD tools, as well as the need to better understand social behavior and decision-making to ensure its implementation. This will require further interdisciplinary research as noted above.
  
  EERI would also like to endorse Objective 4, the need to improve post-earthquake information management. EERI has a long history of leadership in post-earthquake investigations and has looked long and carefully at the issues and challenges that are inherent in improving post earthquake information management. Over the sixty years in which EERI has been involved in post earthquake information gathering and reconnaissance investigations, critical observations that have resulted in changes to codes and practices have largely been accomplished by volunteers. Funds have never been available for the kind of systematic data collection that is required, nor have field data been archived in ways that encourage further analysis or contribute to laboratory research. In EERI's 2003 publication, Collection & Management of Earthquake Data: Defining Issues for an Action Plan, EERI laid out the necessary steps to develop an accessible data repository and data management system. We are particularly pleased to see the development of a national post-earthquake information management system and repository as a strategic priority and look forward to contributing to this effort. Also related to Objective 4, EERI members developed USGS Circular 1242, The Plan to Coordinate Post-Earthquake Investigations, in 2003. We also look forward to working with the NEHRP agencies to bring it up to date as part of this strategic priority.
  
  EERI supports Goal B, the need to develop cost effective measures to reduce impacts on individuals, the built environment and society as a whole. Under separate cover we are sending a copy of an EERI publication, Incentives and Impediments to Improving the Seismic Performance of Buildings, June, 1998, EERI, Oakland, CA. This publication was compiled for the California Governor's Office of Emergency Services and is available from EERI. The ICC may find this publication a useful reference in suggesting specific programs to improve the development of new and more effective mitigation strategies that take into account social and economic factors.
  
  EERI would like to lend our endorsement in particular to Objective 10, the development of comprehensive earthquake scenarios and earthquake risk assessments as a means to achieve Goal C, improved earthquake resilience of communities nationwide. EERI played a lead role in the development of two recent scenarios, one for an earthquake on the Seattle Fault and another for a repeat of the 1906 San Francisco Earthquake. EERI's Northern California chapter is beginning to update a scenario for the Hayward Fault and EERI's New Madrid Chapter is currently working on a new scenario for an earthquake in the New Madrid Seismic Zone. EERI is currently carrying out the development of a National Scenario Workshop for the NEHRP agencies to enable those in seismic regions throughout the country to share information and expertise and gain the necessary tools to initiate scenario development programs of their own. Scenarios allow communities and individuals to personalize risk. We believe that scenarios can be powerful tools, bringing about new policies and programs to mitigate the impact of future earthquakes.
  
  As the principal US society for professionals dedicated to reducing earthquake risk, EERI is particularly supportive of objective 12, promoting implementation of earthquake resilient measures in professional practice and in private and public policies. NEHRP support over the years has been critical to the development of technical meetings, conferences, seminars, publications, and web materials aimed at improving the exchange of information from research to practice and at providing new tools to assist earthquake professionals. EERI stands ready to work with the NEHRP agencies to continue to improve technology and knowledge transfer to the nation's earthquake professionals.
  
  The members of EERI are committed to working with Congress and with elected officials to ensure that adequate funding is available to enable each of the NEHRP agencies to contribute fully to the goals and objectives set forth in this Plan and to enable NIST, as the lead agency, to carry out its mission as assigned in the Earthquake Hazards Reduction Act of 1977, as amended by Public Law 1098-360. As part of this effort we are assembling a team to update the 2003 EERI document Securing Society Against Catastrophic Earthquake Losses: A Research and Outreach Plan in Earthquake Engineering. The revised EERI research and outreach plan, which will be aligned closely with the goals and objectives of NEHRP Strategic Plan, will attempt to summarize advancements since the last NEHRP reauthorization as well as outline the scope and cost of priority activities that will lead to reduced economic and societal losses from future seismic events.
• Comment: The seismologists at the 109 Member Institutions of IRIS applaud the NEHRP secretariat for developing a comprehensive strategic plan focused on mitigating earthquake hazard across the nation. The importance of accelerating the excellent progress that is being made with the ANSS is strongly endorsed by IRIS and its members. IRIS encourages the NEHRP Secretariat to ensure that the final version of the plan includes contributions of the NSF Earth Sciences Division (EAR) to NEHRP—both the EAR-funded infrastructure that should be improved to continue serving NEHRP goals and work that EAR ought to fund in the near future. EAR facilities and activities are implicitly called upon at several points through the April 2008 draft for public comment but some are not explicitly described, in contrast with repeated mention of facilities such as ANSS, NEES and the USGS-operated part of GSN. Specifically:
  • Maximum use of research and data collection facilities (page 13, lines 20–23) requires archiving of data and metadata. As noted in the ANSS Requirements (USGS Circular 1188), the EAR-funded IRIS Data Management Center (DMC) is a model for this necessary function of an advanced system. A Post-earthquake Information Management System (PIMS, page 22, lines 1–9) could use web services and other technologies to integrate, rather than duplicate, facilities that already archive some types of data, including the EAR-funded DMC.
  • Seismic experiments in US cities have mapped details of crustal faults and basin structure that are essential input for predicting strong ground motion. Maximizing use of data collection facilities (page 13, lines 20–23) includes maintaining infrastructure for further experiments, including the PASSCAL Instrument Center (PIC) and the EarthScope Flexible Array Operations Facility (AOF), which are both operated with funding from EAR.
  • International cooperation (page 15, lines 9–20) includes the US role in the International Federation of Digital Seismograph Networks (FDSN). US participation in the FDSN includes EAR-funded operation of the DMC as the core-network archive center for the FDSN, GSN participation in the FDSN, and IRIS's role in FDSN Working Group 5 to foster more international cooperation and open data policies for temporary seismic networks.
  • The importance of subsurface geology to models of earthquake processes is described (page 17, lines 38–39), but no mention is made of the geophysical field work that is necessary to discover subsurface geology. In addition to contributing use of facilities that it funds (PIC, AOF, and DMC) in support of this work, EAR has co-funded field work for several of the experiments because of the fundamental science aspects of the discoveries.
  • Computer-based models of expected ground shaking (page 22, lines 33–41) require basin-scale mapping of faults and structures that can focus seismic waves. The draft plan does not mention EAR-funded facilities that support mapping at this scale, including PIC, AOF, and DMC.
  • NEHRP monitoring networks for crustal strain (page 29, lines 19) that ought to be operated and maintained include EAR funding for the Plate Boundary Observatory (PBO) and San Andreas Fault Observatory at Depth (SAFOD).
  • The draft report notes that measuring aftershock sequences yields data to improve knowledge of stress and strain related to earthquakes (page 29, line 23), but does not note the importance of maintaining instruments that can be deployed quickly to make these measurements, such as the EAR-funded Rapid Array Mobilization Pool (RAMP). An improved RAMP with real-time telemetry and processing ought to be an outcome from this objective. NEHRP activities in the event of a major earthquake (page 41, lines 34–37) ought to include prompt deployment of a dense network of sensors that include seismic stations to measure aftershocks and GPS stations to measure strain, which will be dependent on facilities in operation before the earthquake.
• Comment: As a stakeholder community of earthquake professionals, the Seismological Society of America (SSA)
  • Supports the goals, objectives and strategic priorities of the National Earthquake Hazards Reduction Program (NEHRP) Strategic Plan for Fiscal Years 2008-2012.
  • Recognizes the excellent leadership and coordination shown by all the NEHRP agencies in developing this Strategic Pan, and in particular the role of the National Institute of Standards and Technology (NIST) as the NEHRP Lead Agency
  • Important advances in understanding of earthquake phenomena and effects have occurred as a result of the NEHRP and continued support for this type of basic scientific and engineering research can not be emphasized enough. SSA supports the Strategic Plan Objective to develop the nation's human resource base of earthquake professionals, and recommends that this Objective be considered as a Strategic Priority.
  • The NEHRP has created a scientific infrastructure of research facilities as well as earthquake and tectonic monitoring networks that need to be operated and maintained to provide basic information. This is the backbone of the NEHRP program—without which many of the program advances would not have occurred. Like the NEES infrastructure of engineering facilities there is a parallel seismological infrastructure of data management centers, portable instrument programs and facilities that need to be recognized and supported in addition to the signature ANSS program.
  • The SSA supports the Strategic Priority of a fully implemented Advanced National Seismic System (ANSS) but recommends that the Strategic Plan also give recognition to the roles and needs of the other scientific infrastructure that support the NEHRP as well
• Comment: Prioritization of identified earthquake hazard areas needed. Tools and approaches must also [be] implemented not singularly developed. Emerging info is great but we still need to apply lessons learned from past events. Clear framework for interagency cooperation is a must. Consideration of response philosophies is critical in developing mitigation strategies.
• Comment: One big issue we somehow need to address is that "NSF has made a significant investment in the NEES test facilities, but now the funds available to use these same facilities is woefully short."
  
  I am currently a NEES Board member, and it is quite frustrating to observe this problem close up.
• Comment: I have no real serious disagreements with the NEHRP plan as it exists since it is quite comprehensive and also it is not too specific.
  
  I believe that a simple Seismic Building Rating System will help achieve many of the objectives contained in the plan.
  
  Suggestion: I sent a copy of where we are in a SEAONC subcommittee effort to attempt to get going with this concept, and we are now in the middle of Phase 2—the Summary is self explanatory and it would really help with a number of your Objectives—I am not sure how it might be included or where it should go.
• Comment: I was reviewing your strategic plan I noticed that our organization would be able to provide added value toward achieving some of the objectives of Goal C. The Worker Education and Training Program (WETP) is a branch of the National Institute of Environmental Health Sciences (NIEHS) under the National Institutes of Health with the Department of Health and Human Services. The NIEHS has a long history of involvement with emergency response and preparedness activities. In particular, the NIEHS has extensive experience with OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. The NIEHS WETP received its mandate through the Superfund Amendments and Reauthorization Act of 1986 (SARA). SARA established and funded a grants program for the training and education of workers engaged in work covered by that OSHA standard.
  
  The mission of the WETP is to provide high quality safety and health training and resources for workers handling hazardous materials or involved in responding to emergencies involving hazardous materials. The WETP achieves this, in part, by making awards to a national network of nonprofit safety and health training programs.
  
  Suggestion: The NIEHS program has been funded primarily on the basis of the worker protection statutes of the Superfund Amendments and Reauthorization Act of 1986 (Section 126 of SARA). Since its authorization by Congress in 1986, the NIEHS WETP has been funding the development, deployment, and utilization of state-of-the-art safety and health training for hazardous waste operations workers and chemical emergency responders. In addition, the WETP began administering additional grant awards for training funded by the Department of Energy (DOE) to meet that Department's expanding high hazard operations training needs associated with the massive environmental restoration program being undertaken by the DOE Office of Environmental Management (EM). More recently, additional training grant programs have been executed and managed by the WETP targeting disadvantaged minority young adults (Minority Worker Training Program) and the Brownfields Minority Worker Training Program, delivering comprehensive training to disadvantaged residents in Brownfields communities. The Hazmat Disaster Preparedness Training Program fosters the development of specific training programs for the purpose of preparing a cadre of experienced workers for prevention and response to future disasters.
  
  Through the encouragement of multi-state, university-based and labor union consortia, and the development of other national non-profit organizations which have focused on specific workforce sectors, the program has established technically-proficient curriculum materials and quality-controlled course presentations. These courses have been delivered to hazardous waste workers and emergency responders in every region of the country and have established new national benchmarks for quality worker safety and health training. Our program has also created a national resource of thousands of peer trainers who are available to respond under the National Response Framework (NRF) to provide a variety of health and safety needs assistance as outlined in the NRF.
  
  Over the last fifteen years, NIEHS WETP has developed significant experience in disaster response and related cleanup activities. The Agency has assisted in the rescue, recovery and cleanup operations at the following disasters: Oklahoma City bombing, World Trade Center (WTC) terrorist attacks, 2001 anthrax attacks, Hurricanes Katrina and Rita, and the October 2007 Southern California wildfires. As a participating agency under the Worker Safety and Health Support Annex of the NRF we continue to work to empower the responders and workers to recognize and take appropriate actions to prevent, avoid, and protect themselves from hazards associated with disaster sites.
  
  We continue to address the health and safety hazards associated with the 15 National Disaster Scenarios which have included Radiological Dispersal Devices, Avian Influenza, Hurricanes and our current project, earthquakes. If there is anyway we can be of assistance in achieving your goals don't hesitate to contact us.
• Comment: The NEHRP Strategic Plan is well done, but it could be improved by emphasizing more the need for conducting research utilization and synthesis projects to adopt and adapt current research into earthquake and structural engineering practice.
  
  The prior Strategic Plan recognized this technology transfer gap.
  
  Suggestion: In reality, the current technical basis for earthquake engineering practice is the direct result of technology transfer (research to practice) efforts carried out by the Applied Technology Council and the Building Seismic Safety Council. These organizations, with funding from NEHRP, have developed significant new engineering resources and applications, including standards of practice, for (1) seismic design of new buildings, including the introduction and use of new technologies such as seismic isolation and energy dissipation; (2) rapid and detailed seismic evaluation of existing buildings; (3) seismic rehabilitation of existing buildings, including both methods and techniques; and (4) the evaluation and repair of earthquake damaged buildings. These are the pinnacle NEHRP achievements, involving synthesis and development efforts of a broad array of the nation's leading practicing engineers and researchers, and utilizing to the extent practical newly available research, most notably the USGS seismic hazard maps.
  
  The Strategic Plan could also be improved by elevating achievements and programs relating to seismic evaluation and rehabilitation to that given to the seismic design of new buildings. In fact, it is likely that more NEHRP resources were directed at improving techniques and standards of practice for seismic evaluation and rehabilitation than were used to improve techniques and standards of practice for new design. When one reviews the list of available NEHRP publications relating to seismic design of new buildings, versus the seismic evaluation and rehabilitation of existing buildings, it seems likely that seismic evaluation and rehabilitation will lead in both numbers and significance. And this is as it should be, given the risks now faced by the nation.
• Comment: As a group, we are generally very pleased with the draft strategic plan. We do, however, urge the Interagency Coordinating Committee (ICC) of NEHRP to carefully consider the comments and recommendations of the Advisory Committee on Earthquake Hazards Reduction (ACEHR) as well as the specific comments submitted by the NEHRP community.
  
  The NEHRP Coalition encourages comprehensive, realistic, and affordable measures for reducing the harmful effects of earthquakes. The Coalition represents the views of over 250,000 earthquake professionals—scientists, engineers, architects, and emergency management leaders of the earthquake community.
  
  Suggestion: For more than 30 years, NEHRP has provided a wealth of crucial scientific research and structural analysis to seismologists, engineers, urban planners, emergency managers and the public. Cost-effective mitigation techniques derived from NEHRP work helps to save lives, reduce infrastructure losses and eliminate unnecessary design costs through more accurate risk assessment. The U.S. Geological Survey (USGS) has conducted research on the mechanisms and causes of earthquakes, helps to maintain global, local and regional earthquake monitoring systems, produces earthquake hazard maps and notifies the public about earthquakes nationwide and throughout the world. The National Science Foundation (NSF), through it's grants to university researchers, improves our understanding of earthquake processes, identifies the level of risk in specific areas, integrates earthquake science and engineering practices, develops new engineering analysis and design techniques and provides training for the next generation of earthquake specialists as well as education for the public. The Federal Emergency Management Agency (FEMA) leverages small amounts of funding into an impressive series of design guidelines, standards and codes that have spread the experience of a few to engineers, urban planners and emergency managers nationwide. The National Institute of Standards and Technology (NIST) develops standards for Federal buildings that have encouraged stakeholders nationwide to recognize the earthquake vulnerabilities of their communities. It has been a successful program with significant results.
  
  Specific comments with regards to the NEHRP Strategic Plan
  
  The NEHRP strategic plan should, and the draft does appear, to reflect the integrated nature of the program. We are pleased that it is a fairly precise document which reflects the following important principles:
  • Implement the provisions of Title 1 of the P. L. 108-360, "National Earthquake Hazards Reduction Reauthorization of 2004" pertaining to the leadership of NEHRP.
  • Develop and conduct programs and projects in basic seismology, seismic engineering, architectural, geologic, and social sciences areas aimed at the development of improved earthquake codes and standards and other seismic risk-reduction measures.
  • Prepare guidance and related technical documents for the use by design professionals and of private-sector organizations engaged in the development of building codes and standards.
  • Establish programs and projects to encourage state and local governments to adopt and enforce measures aimed at lessening the seismic risks in their respective jurisdictions, to engage in outreach and educational programs to reach the general public and to foster the efforts of private organizations engaged in complementary seismic mitigation efforts.
  • Establish programs and projects to lessen both the threat to life safety and the economic losses resulting from seismic damage to buildings and facilities.
    
    
  The NEHRP Coalition believes that the critical role of the Interagency Coordinating Committee (ICC) cannot be overstated and its leadership must be properly reflected in the strategic plan. The Coalition feels there is a renewed opportunity to realize the full benefits of a truly integrated program. In the past, there has been a great deal of accomplishment, but it has been unnecessarily limited by the lack of full integration of the program elements.
  
  Equally important to the success of NEHRP is the Advisory Committee on Earthquake Hazards Reduction (ACEHR). The role of the Advisory Committee as defined in the Public Law is to assess: trends and developments in the science and engineering of earthquake hazard reduction, including predictive capability; the effectiveness of NEHRP in carrying out its activities; the need to revise the program; and the management, coordination, implementation, and activities of the program are all vital to enhancing the effectiveness of NEHRP. We urge that the ICC carefully consider the comments of ACEHR in finalizing the strategic plan.
  
  However, the most important element of a NEHRP strategic plan, one that should be emphasized in every goal or objective that is set, is the importance of putting the research results into practice and getting collected data and analysis into the hands of those who need it. The ultimate goal of NEHRP is the protection of life and property during and after an earthquake. To achieve that, the research conducted and the data collected under NEHRP must be utilized. Successful research needs to become successful practice and the NEHRP strategic plan must make this its overriding priority.
• Comment: I only became aware of the referenced Plan two days ago, which obviates the possibility of providing an extensive, good faith comment. Therefore, first of all, I suggest that the notice and comment period be extended, and the availability of the document be given wider dissemination. I acquired the document only through the good offices of a colleague. There are many outside the community whom this document defines as the "professional community," who might have interest in responding.
  
  2. My colleagues, [names deleted], and I hold US Patent 7,277,797, which addresses a viable means of predicting earthquakes ("EQs"). Our methodology exploits pre-EQ-induced perturbations in the total electron content of the ionosphere, to effectively provide two-to-three days warning prior to the onset of an EQ (along with other technical enhancements to drive down the geo-positional uncertainty of the epicenter to less than 40 kilometers). The method described therein has been rigorously tested and demonstrated. Our system could be implemented along the entire West Coast, including the States of California, Oregon, Washington, Idaho, Utah, and Nevada, at a cost of approximately $2.8 million, and an annual operating cost of about half that amount. We could begin making operational predictions of all EQs, magnitude 4 and above, within 18 months. Our Pfa and Pd are excellent: we predict EQs correctly, thus far, missing none in our field tests.
  
  3. The NEHRP Strategic Plan is woefully inadequate in addressing "prediction and warning," which seems to be mentioned only once (based on my short review), and that is on page 18, appearing more or less as an after-thought, rather than as a major theme in the document. The Plan cites 3 goals, none of which relate to "prediction." The Plan lists 14 objectives; none of those relate to "prediction." There are 9 "cross-cutting Strategic Priorities" listed, and again, "prediction" is not mentioned.
  
  The Plan implies that the first and foremost consideration is public safety. To me, that warrants a national responsibility to warn the public of an impending event, prior to the event. This Plan omits in-depth discussion, or even recognition of any such responsibility.
  
  Instead of a logical and fundamental objective focus on prediction and warning, the Plan is 99% dedicated to sustaining and extending a 31-year history of support for seismologists in academia, to funding an alphabet-soup of organizations directed toward "resilience and post-EQ reaction," to improved "statistical record-keeping of casualties and damage," and to "continuing expansion of networks of seismic sensors," (which sense localized, micro-responses to earth processes, rather than capturing and analyzing the macro character of plate electro-dynamics." Contrast those functions with the payoff which could be possible with accurate prediction of EQs—days and hours prior to the event.
  
  Our own exploitation of the ionosphere, as a "sensory shield" above the earth, capable of integrating localized clutter and masking noise sources into the background, underscores the limitations of the Plan's seismic focus. Knowing where and when EQs occur, and the results, is a valid academic interest. Knowing that an EQ is going to occur in the next day or two, or in the next few minutes—information which we can provide through our technology—is of vastly greater importance, and in the public's interest. If the NEHRP is to truly serve the public, this narrowly cast Plan should be redrawn to focus on prediction and warning, on preemptively saving lives and property, and not on generating statistical bases or post-EQ activity and reporting.
  
  4. One of the least erudite objections to predictions is that "predictions must be 95% accurate or they are worthless." Why 95%, and not 94% or some other arbitrary and capricious number? We routinely forecast tornados which do not materialize, we forecast hurricane tracks and landfalls which deviate greatly from reality. We evacuate millions of people from homes in Key West, Miami, and New Orleans, only to find a sunny day instead of a storm surge. Katrina's landfall was uncertain as late as 24 hours before it hit New Orleans. The EQ community should, and can be doing at least that well.
  
  5. We—the public, scientists, and government officials—have an overriding responsibility to our nation and the public. If the 1906 San Francisco EQ were to be repeated today, the loss would be horrendous, and FEMA, USGS, NEIC, and all the other agencies would collect data and respond ex-post-facto. In contrast, my company would look at the archival data from the many GPS ground station receivers in the San Francisco area, we would reconstruct the ionospheric signatures for the week preceding the EQ, and we would see clearly the geophysical changes imminent, available prior to the catastrophe. Using the available data, our know-how (and, if our system were in place), we would have predicted that EQ. I do not want that failure to act, on my conscience. How much better it would be if we forecast the onset of that EQ, truly serving the public interest.
  
  6. I have attached a few graphics which depict aspects of our methodology, showing what is possible today. This note, augmented by a scientifically-qualified reading of our patent, provide the background necessary for NEHRP to understand that there is a better approach to this problem. I recommend that you take this Plan back to the drawing board and redraft it to be responsible—not to the "professional community"—but to the public which NEHRP has a duty to serve.

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