The group's proposal suggests linking all existing communications databases -- such as state rural water associations' membership lists, rural water associations' field work reporting data and EPA and Agriculture Department databases -- to ensure DHS is able to reach rural utilities in cases where security information must be communicated.
NRWA says in its proposal that a comprehensive database is needed because of numerous instances where EPA or DHS have been unable to communicate such information to small utilities, such as distribution of EPA's "threat assessment" document several years ago. NRWA says the document, which gives utilities general information on how to protect their facilities against terrorist threats, never reached many small utilities in EPA's initial attempt because "many of EPA's addresses were incorrect, the letters never made it to the correct local officials upon delivery, many systems could not get the fax to go through" and several other complications.
NRWA also suggests that its communication system network would rely on state rural water associations to deliver security information, rather than having DHS relay the information; and allow rural utilities to base their security plans on measures that improve security on a site-specific basis rather than conforming to a national set of security guidelines.
In addition to proposing the communications network, NRWA plans to send additional letters to DHS outlining the group's suggestions for how the department should peer review communities' security plans and encourage communities to take corrective action on vulnerabilities identified in those plans.
A DHS spokesman says the department had not yet received NRWA's letter, and DHS was not familiar with the proposal.