On Precursor Crimes

Just a quickie on precursor crimes. In The Washington Institute for Near East Policy's PolicyWatch/PeaceWatch Michael Jacobsen writes:

[Europe and America's] preventive strategy [regarding terrorism] has revolved around an increasingly aggressive law enforcement approach. In 2006 alone, for example, European authorities arrested a total of 260 terrorist suspects. Most of these individuals were charged not with plotting attacks, but with a variety of other terrorism-related offenses such as financing, recruiting, and facilitation.

Also see these other posts re: precursor crimes.

Pandemic Preparedness: Adequate?

A brief GAO report asks if we're really prepared, especially at the federal level, for a flu pandemic. The short answer is, no. Although we have a National Strategy for Pandemic Influenza and an Implementation Plan for the strategy, critical questions remain. For one thing, it's not clear how everyone will play in the sandbox together:

Key federal leadership roles and responsibilities for preparing for and responding to a pandemic continue to evolve and will require further clarification and testing before the relationships of the many leadership positions are well understood. Most of these leadership roles involve shared responsibilities and it is unclear how they will work in practice. ...

Several federal leadership roles involve shared responsibilities for preparing for and responding to an influenza pandemic, including the Secretaries of Health and Human Services and Homeland Security, the Administrator of the Federal Emergency Management Agency (FEMA), a national Principal Federal Official (PFO), and regional PFOs and Federal Coordinating Officers (FCO). Many of these leadership roles and responsibilities have not been tested under pandemic scenarios, leaving unclear how all of these new and developing relationships would work.

Specifically:

[S]ince a pandemic extends well beyond health and medical boundaries, to include sustaining critical infrastructure, private sector activities, the movement of goods and services across the nation and the globe, and economic and security considerations, it is not clear when, in a pandemic, the Secretary of Health and Human Services would be in the lead and when the Secretary of Homeland Security would lead.

Moreover, under the Post-Katrina Emergency Management Reform Act of 2006 (referred to as the Post-Katrina Reform Act in this testimony), the FEMA Administrator was designated the principal domestic emergency management advisor to the President, the HSC, and the Secretary of Homeland Security, adding further complexity to the leadership structure in the case of a pandemic.

Another question: How is this plan coordinated with the North American Plan for Avian & Pandemic Influenza? (See this post for background.)

Exercises might reveal potential problems, but:

[O]nly one national, multi-sector pandemic-related exercise has been held, and that was prior to issuance of the Plan.

GAO also points to in this Strategy and Plan that ought to be included in such documents:

The Strategy and Plan do not fully address the characteristics of an effective national strategy and contain gaps that could hinder the ability of key stakeholders to effectively execute their responsibilities. Specifically, some of the gaps include

• The Strategy and Plan do not address resources, investments, and risk management and consequently do not provide a picture of priorities or how adjustments might be made in view of limited resources.
• State and local jurisdictions were not directly involved in developing the Plan, even though they would be on the front lines in a pandemic. Officials told us that state, local, and tribal entities were not directly involved in reviewing and commenting on the Plan, but the drafters of the Plan were generally aware of their concerns.
• Relationships and priorities among action items are not always clear.
• Performance measures are focused on activities that are not always linked to results.
• The linkage of the Strategy and Plan with other key plans is unclear.
• The Plan does not contain a process for monitoring and reporting on progress. While most of the action items have deadlines for completion, ranging from 3 months to 3 years, the Plan does not identify a process to monitor and report on the progress of the action items nor does it include a schedule for reporting progress.
• The Plan does not describe an overall framework for accountability and oversight and does not clarify how responsible officials would share leadership responsibilities.
• Procedures and time frames for updating and revising the Plan were not established.

The lack of engagement with state and local officials is especially troubling, especially given the lack of clarity regarding roles. It's just this sort of thing that collaborative effort should be able to resolve.

New Massachusetts State Homeland Security Strategy

Massachusetts has released a new state homeland security strategy. It's an all-hazards strategy, which reflects the experience of Hurricane Katrina and the risk of other natural hazards such as pandemic flu.

The strategy lists three major goals:

Our obligations, from the state’s perspective, whether we are planning for response to a terrorism incident, detecting a potential influenza outbreak, managing a major fire, or preparing for a potential hurricane, are guided by three major goals:

1) to create a common operating picture among all homeland security and public safety stakeholders;
2) to strengthen and expand partnerships across assets and capabilities; and
3) to focus efforts on private sector and public participation in prevention and preparedness.

These are laudable goals - it's especially welcome to see the explicit focus on private sector involvement (more on that later). It covers the whole range of preparedness activities, from prevention to response and recovery:

[T]he state is ultimately responsible for ensuring both effective prevention and effective response and recovery.

Prevention primarily relies on intelligence that's funneled through the state's Fusion Center:

The intelligence aspect of prevention, in terms of securing critical infrastructure, maintaining resource databases, and all aspects of the Commonwealth Fusion Center, contributes to prevention by informing law enforcement and public safety officials about vulnerabilities. Once vulnerabilities are recognized, we can begin to find solutions to prevent incidents.

Initial thought - this is focused on vulnerabilities, but risk is not just vulnerability. Calculating a threat involves not just vulnerability, but likelihood and consequence as well.

To organize the effort, they're using not only the Fusion Center. For coordination of recovery efforts, Massachusetts is using a new, collaborative organization:

[W]e have launched the Massachusetts Recovery Alliance that will convene all relevant parties to ensure that all efforts – from building inspections, to federal support, to workforce replacement – are properly integrated after a disaster.

They also have an Implementation Team that oversees state support of HSPD-8, "National Preparedness":

The HSPD-8 Implementation Team is charged with assessing the ability of the Commonwealth to respond to catastrophic events. Since its inception in 2006, the team has identified and ranked existing gaps in capacity and compiled them into a matrix that aids in establishing funding priorities and gives direction and focus to state and regional capability improvement plans.

For implementation purposes, the state has been divided into 5 geographic regions:

Liaisons from EOPSS Homeland Security Division provide guidance and oversight to each of five geographically designed regions - the Northeast, Southeast, Central, Western, and Metro Boston (UASI) - which were created to support strategic planning and operational coordination at the local level. Regional Planning Councils for each region are responsible for developing and guiding the implementation of regional homeland security plans described in this document. ... Five Regional Homeland Security Advisory Councils serve as the governance body (both policy-making and administrative) for each of the regions.

Each region is responsible for developing local relationships (very good) and is relatively autonomous in setting priorities:

Substantial state and local collaboration and coordination have resulted from the working partnerships of the regions. In furtherance of SHSS activities, each region has individually dedicated homeland security resources to collaboration, planning, equipment, training, and evaluation.

• The Northeast Region has utilized homeland security funding to procure a variety of emergency supplies, coordinate first responder activities, and implement school safety mechanisms.
• The Southeast Region has made significant strides in improving interoperability and incident command training.
• The Central Region has expanded the capability of communities to recover from large scale incidents through the procurement and deployment of emergency equipment.
• Major accomplishments of the Western Region include interoperability and information sharing projects.
• The Metro Boston Homeland Security Region (MBHSR) has improved intelligence and information sharing, as well as communications interoperability.

In terms of implementing the states three major goals, the strategy briefly outlines some of the implementation activities that should go on statewide. Under the first goal of Creating a Common Operational Picture, the initial emphasis is on the fusion center:

Pursue effective prevention efforts through analysis of risks: In order to understand the strategic threats that face the Commonwealth and take the proper and appropriate protective measures, public safety and public policy officials need access to timely, accurate, and actionable intelligence and information. The Commonwealth Fusion Center is at the center of the state’s efforts to receive, produce, and share intelligence assessments and reports with our local, state, and federal partners. To that end, the Fusion Center has recently incorporated personnel and systems from the Federal Bureau of Investigation (FBI) and the U.S. Department of Homeland Security (DHS) to support the seamless exchange of information and intelligence regarding threats to the nation and the Commonwealth. These assessments and related products are regularly shared with key stakeholders for tactical support, situational awareness, and strategic planning purposes.

The top-down emphasis is a bit worrying - they're incorporating federal personnel into the fusion center. Let's not forget threat information that comes up the chain as well. Hopefully the threat information won't come mostly from "above."

However, it's nice to see that the info on vulnerability of particular assets will come from the local level, because locals know that best. Locals can also provide important info that helps determine likelihood and consequences:

Among the Commonwealth Fusion Center’s intelligence assessments and alerts agenda, a present primary focus is the recent adoption of the Automated Critical Asset Management System (ACAMS), a statewide inventory tool to categorize and prioritize critical infrastructure. The process of assessment includes leveraging existing state and local partnerships with public safety stakeholders and other subject matter experts to collect critical asset data by training and providing them access to ACAMS. These teams will bring together public safety professionals with other subject matter experts (e.g. structural engineers) to produce in-depth, robust vulnerability assessments of critical infrastructure and key resources. When joined with the ongoing assessment of potential threats conducted by the Commonwealth Fusion Center, a clearer assessment of risk in the Commonwealth will emerge.

Seems to me that if the fusion center gets information on threats and vulnerabilities from local personnel, as well as relevant info regarding likelihood and consequences, and really fuses it with the information on threat (as well as info relevant to likelihood and consequences) that comes from the FBI and DHS, then the fusion center will really be doing its job - fusing information from all levels to create an accurate picture of the threat. That's a good approach.

Moving on to some of the other objectives of the strategy...you don't always see this one:

Prepare the Commonwealth for Mass Evacuation and Shelter: To date, there are numerous local and state plans. However, they can not each stand alone and succeed. We need to ensure that the plans are fully integrated, that the expectations of one jurisdiction merge with another, and that the state, through the Massachusetts Emergency Management Agency (MEMA), is able to understand and assist in those efforts. ... This overall state and local effort has three interrelated parts – traffic plans, sheltering capacity assessments, and focus on individuals requiring specific assistance.

Next, a few notes on the second major goal, Strengthen and Expand Partnerships for Prevention and Preparedness. This is good to see:

Integrate Public Health Preparedness into Homeland Security Efforts: Protecting public health is an integral part of an all hazards approach to homeland security, whether it be detecting a naturally occurring or man-made public health threat, or protecting our first responders during a potential chemical, radiological, or biological incident.

But ... is there enough capability built into the public health system to accommodate a catastrophe? (See these two posts.) As for distributing medicines their plan is:

The foundation of the Boston plan is the staffing and operation of large dispensing clinics, located in schools and community centers all over the city, where residents would be able to pick up medications for themselves and their families.

On port security, just an interesting factoid:

[W]e continue to work with affected localities and the state of Rhode Island to oppose the proposed LNG terminal in Fall River. The Commonwealth opposes the proposed terminal based on the potential dangers associated with the storage and transfer of LNG and the U.S. Coast Guard report that expresses safety concerns regarding the transfer of LNG through the proposed waterway.

The risk of LNG to surrounding communities is somewhat unclear. Interesting that Massachusetts is taking this stand.

On Goal #3: Focus on Private Sector and Public Participation in Prevention and Preparedness, it's interesting how many of the specific implementation activities under this goal relate to personal preparedness:

Enhance Personal Preparedness: Help Us Help You Campaign - EOPSS is planning a wide variety of events for September, all of which will reinforce the idea that doing a little advance preparation on an individual level will help the government help you in a time of emergency.

Address the Needs of Individuals Requiring Specific Assistance: Statewide Individuals Requiring Specific Assistance Task Force on Emergency Preparedness: The intention is to enhance emergency preparedness planning for people with specific and/or functional needs and to include them in the planning process as well as exercises and drills.

Continue Community Outreach Efforts: Engage and empower immigrant populations. In order to change the pattern of exclusion, outreach efforts have been employed to engage and empower isolated groups.

I'd actually like to see more detail on how large private sector entities will be incorporated into the planning and preparation process (other than the very welcome involvement in ACAMS noted above). Often, critical businesses such as chemical plants, oil refineries, utilities and so on, are reticent to share information because of proprietary concerns.

While it is certainly important for individual citizens to be prepared, it's even moreso for the owners and operators of critical infrastructure elements to be coordinated with the state's preparation and response.

Update Sept. 26, 2007: I'd forgotten about this audit from last year that found Massachusetts unprepared (also see my post). The state Senate committee that oversaw the audit found four areas of concern:

• The state’s insufficient oversight of homeland security planning by cities, towns and the state’s agencies and authorities;
• The state’s failure to provide first responders with the proper means to protect against terrorist activity and natural disasters;
• The state’s inadequate communication of the statewide strategy; and
• The state’s unsuccessful implementation of its homeland security plan.

NYC Public Health System Not Fully Prepared

Not terribly surprising:

New York City's health care system is not prepared for a major disaster such as a large-scale attack, hurricane or pandemic, health care and disaster planning experts said.

The city, struck in the September 11 attacks and a world financial center, is vulnerable due to underfunding and a lack of understanding of the possible complexities of a crisis, officials from city hospitals and emergency services said this week at a conference on disaster preparedness.

"We have no idea what a prepared New York is. What we're doing now is random acts of preparedness that all together don't really amount to an appropriate safety net," said Irwin Redlener, director of the National Center for Disaster Preparedness at Columbia University's Mailman School of Public Health.

"We're in a very, very bad place."

There's a problem - long known - with a lack of excess capability. NYC, despite its high-profile status, is not immune to the problem:

Brian O'Neill, who heads emergency services for the North Shore - Long Island Jewish Health System, said the city's emergency services have the potential to move large numbers of people injured in a catastrophe, but not necessarily the hospital capacity to deal with them.

"We don't have 20,000 open beds ... for hospitals to absorb that," O'Neill said. "We would have to rely, at that point in time, for long-term solutions from the federal government."

Columbia's Redlener said hospitals would be immediately overwhelmed in such a situation and the number of deaths would balloon.

Like I said, all of this is not terribly surprising. Given the threat of pandemic flu, there has been a lot of study of our public health system. The basic problem is that we've given up excess capability for the sake of efficiency. (Which makes perfect sense for most businesses but is debatable in the healthcare field, where you need to be able to accommodate surges in demand.)

The Trust for America's Health reported late last year that we don't have enough beds for a flu pandemic. (Also see my post.)

Half of states would run out of hospital beds within two weeks of a moderately severe pandemic flu outbreak.

Last December, the Trust for America's Health, in it's "Ready or Not?" report, found that:

Forty states and D.C. have a shortage of registered nurses.

Six states cut their public health budgets between FY 2004-05 and FY 2005-06. As of FY 2005-06, the median state funding for public health is only $31 per person per year.

And that the public health system is hampered by:

• Lack of clear roles for the various state, local, and federal agencies.
• Limited coordination among the levels of government, including determination of how federal assets would be deployed to states and localities, and across jurisdictions, such as sharing assets and resources among states.
• No minimum standards, guidelines, or recommendations for capacity levels or services required of state and local health departments. This results in major differences in services and competencies across state and local agencies.

Public health officials in NYC are seeing the effects of this lack of clarity:

Bruce Logan, Chief of New York Downtown Hospital's Department of Medicine, said he was unable to get federal funding for an expansion of the hospital's emergency room, despite being four blocks away from Ground Zero where the World Trade Center's twin towers were destroyed on September 11 and the first hospital to respond to the attacks.

"We're in the financial capital of the world ... I see that emergency room as an element of our national defense," Logan said. "Unfortunately, I can't get our government officials -- especially the state and federal ones -- to see it the same way."

Public health is like anything else: You pays your money, you takes your chances. And we are taking our chances, that's for sure.

(Note: Late in 2007, we're supposed to get an updated report on the status of public health preparedness from the CDC.)

Status Report on the Information Sharing Environment

The Program Manager of the new Information Sharing Environment (PM-ISE) just released a new status report on the Information Sharing Environment. (For background on ISE, also see prior posts like these, especially this one.) The PM-ISE produced an implementation plan in November 2006; and since then they've been working to build the system.

Starting with the small stuff, the report gives us an interesting analogy to describe the ISE:

The ISE is not a new, independent information system. ... The ISE is a system of walkways, skyways, and corridors connecting the homeland security, intelligence, defense, law enforcement, and foreign affairs communities and the users of terrorism-related information within those communities.

Hmm ... sounds futuristic ... [cue the theremin] ...

Anyway:

As you might expect, the status report reflects a lot of initial planning and organizational activity. Yet it also sheds some light on DHS' priorities. For sharing information with state, local, and tribal agencies, there is a continued emphasis on fusion centers - almost to the point of total dependence:

State and major urban area fusion centers are vital organizations and are critical to sharing information related to terrorism. They will serve as the primary focal points within the State and local environment for the receipt and sharing of terrorism-related information, while at the same time also handling “all crimes” and “all hazards” related information. ... Agencies will provide terrorism-related information to state, local, and tribal (SLT) authorities primarily through these fusion centers.

Comparing the two bolded bits above, I like the first one a lot better. It emphasizes sharing and receiving information. The second implies that information-sharing is one-way. Hopefully I'm just being paranoid. The status report also says:

As part of the ISE, State and major urban area fusion centers will blend Federal and local information and produce informational products that support the needs of law enforcement and other State and local executives as they develop strategic priorities for their Agencies and, at the same time, produce products that will support the needs of individual police officers, deputy sheriffs, emergency managers, homeland security officials, and others who work with community members to prepare for and prevent crime, violence, and disorder.

They're aiming to network the fusion centers - a good approach:

Pursuant to Presidential Guideline 2, the Federal Government is promoting the establishment of an integrated network of fusion centers to facilitate effective nationwide terrorism-related information sharing. ... .

One question: Last November's implementation plan called for the creation of "hub" fusion centers: "DOJ and DHS will work with Governors or other senior State and local leaders to designate a single fusion center to serve as the statewide or regional hub to interface with the Federal government and through which to coordinate the gathering, processing, analysis, and dissemination of terrorism information."

But the word "hub" does not appear in the status report. Has this idea been abandoned, or is it just further down the road?

Here's how they're organizing the effort:

An interagency Fusion Center Coordination Group (FCCG) has been established. Co-chaired by DHS and the FBI, this group, with the full participation of State and local officials, is responsible for ensuring that the Federal Government’s efforts to work with State and major urban area fusion centers are coordinated and carried out in a manner consistent with the President’s direction.

The Interagency Threat Assessment and Coordination Group (ITACG) is the component within the NCTC that enables and ensures the timely and consistent Federal government-wide coordination of intelligence reports regarding terrorist threats and events that are intended for dissemination to SLT authorities and the private sector.

Inclusion is good:

There has been active participation by SLT government officials in all activities related to the development and design of the ISE. The ISC established a SLT Subcommittee to provide input regarding the needs and capabilities of SLT and SLT representatives were actively involved in drafting the ISE IP. Representatives also are involved in ISE-related working groups focused on implementing the ISE ...

And there is money:

DOJ and DHS are working together to ensure that relevant Fiscal Year (FY) grant programs prioritize efforts to establish fusion centers (first done for FY2007).

And the feds will be involved, in-person:

FBI and DHS are developing an integrated deployment plan to ensure both organizations deploy Federal personnel to State and major urban area fusion centers in a coordinated manner.

But then .... there's this:

Where practical, Federal organizations will assign personnel to fusion centers and, to the extent practicable, will strive to integrate and collocate resources.

"Where practical"? "To the extent practicable"? That's no way to communicate a firm commitment to the effort, especially considering that a recent CRS report on fusion centers found that "federal participation in state and regional fusion centers appears to influence the relationship between levels of government, state, and local access to information and resources, the flow of information/intelligence, and maturation with regards to intelligence cycle functions ... In general, fusion centers collocated with a federal agency reported favorable relationships with that agency. This was often in stark contrast to the views of other fusion centers not collocated with a federal agency(s)."

Hopefully I'm just still being paranoid. A few more uncoordinated notes:

On the architecture:

During this past year, the PM-ISE introduced the ISE architecture and standards framework, a cross-community, perpetuating framework to help ISE participants adjust, plan, install, and operate current and future information resources that form the infrastructure fabric of the ISE.

On creating a culture of sharing:

Development of a strong information sharing culture will require both the resources and commitment to improve current sharing practices and policies, and the accountability to ensure that the improvements are implemented.

True enough, but they have a long way to go. They're just starting to develop the training on core concepts, both for federal agencies and SLT:

“Core” awareness training and Agency-specific training are currently under development and review by the ISC Training Working Group.

Furthermore, the ISC Training Working Group will assist DOJ, DHS, and FBI in the development of information sharing training guidelines for use by SLT governments.

A last note on private-sector sharing and how it's envisioned:

The Critical Infrastructure Partnership Advisory Council (CIPAC) is the primary mechanism through which this coordination takes place. The CIPAC facilitates decision-making across Federal, SLT government, and private sector partners to support ISE-related policy, strategy, plans, issues, and requirements development.

They're going to network with the Sector Coordinating Councils and Government Coordinating Councils created under the National Infrastructure Protection Plan. (Though those are still under development, too.)

WHO Guidelines Mental Health and Psychosocial Support in Emergency Settings

The WHO's Inter-Agency Standing Committee Task Force on Mental Health and Psychosocial Support in Emergency Settings has developed new guidelines for providing psychological support during emergencies. A few quick notes:

The core idea behind [these guidelines] is that, in the early phase of an emergency, social supports are essential to protect and support mental health and psychosocial well-being.

Scientific evidence regarding the mental health and psychosocial supports that prove most effective in emergency settings is still thin. ... The focus of the guidelines is on implementing minimum responses, which are essential, high-priority responses that should be implemented as soon as possible in an emergency.

[This document] calls for a single, overarching coordination group on mental health and psychosocial support to be set up when an emergency response is first mobilised.

The most practical part of the doc is the matrix of interventions (starts on page 19 of the doc), which defines general actions that should be considered during the preparedness phase, in the midst of the emergency, and during the long-term response and recovery phase.

All things considered, this is a quite useful document for preparedness professionals.

How to Stay Put

In a new report, the Redefining Readiness Workgroup argues that, with better preparedness on the part of communities, citizens can successfully shelter in place in the event of an emergency:

In 2004, the Redefining Readiness study found that many people will not be able to shelter in place in an emergency. Exploring how the American public would handle a “dirty bomb” explosion, the study found that only three-fifths (59%) of the population would stay inside a building other than their own home for as long as officials told them. This is cause for concern because people who do not shelter in place will endanger themselves and others. When they go outside, they will expose themselves to toxic dust and radiation, and when they open the door to leave, they will put others in the building at risk by letting dust and radiation inside.

The Redefining Readiness study showed that three-quarters of the people who would not be able to shelter in place under existing conditions would do so if certain issues were addressed.

To examine how to resolve these issues, the RR Workgroup conducted discussions in a variety of communities, in which a number of residents examined the problems they might experience in a sheltering-in-place event. Many of the findings are pretty obvious, but a few are worth highlighting:

People can’t protect themselves by sheltering in place unless they have timely, specific, and believable information about the emergency.

Informing people about the emergency and what to do is important, but the ability of people to protect themselves by sheltering in place depends on a lot more than communication and public education.

Much of what people and organizations currently are being told to do does little to help and sometimes makes matters worse. ... Currently, the public is being instructed to keep a supply of food and water in their homes, and most keep their medications there as well. But in a shelter-in-place emergency many people will need to take shelter in buildings other than their homes ...

Managers are also being told to identify “safe rooms” where people can go to be protected from toxic substances outside. But while detailed instructions are usually given for sealing the room, little or no attention is paid to identifying and preparing rooms that:

(1) can accommodate the number of people who are likely to need shelter;
(2) give the people inside safe access to the supplies and facilities that are critical to meeting their basic, medical, and emotional needs;
(3) assure breathable air and tolerable temperatures; and
(4) minimize other conditions that can provoke unruly or violent behavior.

Rather than tell people what to do, the RR Workgroup presents a series of questions for citizens to think about, in 4 contexts:

• Households
• Workplaces
• Childcare settings, including schools
• Government settings

The questions provide good food for thought, but some of them are general and of limited use to a person without specific information about the threat. For example:

How will we be protected from toxic substances outside if we are some place else at the time of the emergency, such as at work, school, day care, shopping, or in a restaurant?

The answer depends on which toxic substance you're talking about, where you are in relation to it, what your options are for sheltering in place, etc.

My biggest question is simple: How do you ensure that people will drill it? Compared to other, more common risks (e.g., fires, storms), accidents or attacks that might involve sheltering in place are relatively rare. Especially in contexts such as workplaces and schools, employees and students won't act correctly in an emergency unless they've drilled it.

The Smartest Way to Spend $22 Million?

Do we need this?

H.R. 1955 would direct the Department of Homeland Security (DHS) to establish a university-based Center of Excellence for the Study of Violent Radicalization and Homegrown Terrorism in the United States. The bill also would establish a commission to investigate the causes of terrorist acts committed by persons raised or living in the United States and would require DHS to prepare reports on certain issues relating to domestic terrorism.

CBO estimates that the agency would spend about $22 million over the 2008-2012 period to implement the legislation.

It sounds like an attempt to centralize and formalize the study of extremism and terrorism. But the marketplace of ideas is a better forum for working this out.