Cover Letter

August 28, 2018

Honorable Eric Garcetti, Mayor
Honorable Michael Feuer, City Attorney
Honorable Members of the Los Angeles City Council

Re: Alert and Aware: Modernizations to Improve NotifyLA, the City’s Emergency Mass Notification System

Emergencies are inevitable in any metropolis, especially one as vast as Southern California, where millions of residents, people and visitors live and work within urban landscapes, hillsides, mountains and major airports. Challenging cityscapes and an increasing population keep first responders busier than ever and necessitate an even more comprehensive notification system to keep Angelenos safe and informed.

Both the Los Angeles Police (LAPD) and Fire (LAFD) departments operate their own notification systems for certain emergencies. The City’s system that is able to reach the most people in case of an emergency, however, is NotifyLA , the system run by the Emergency Management Department (EMD). This system is able to send immediate alerts to landlines or cell phones to those who subscribe to the free service – and it can also send mass emails and area-specific wireless emergency alerts.

Unfortunately, the City is not using NotifyLA as effectively as possible. Its notifications are inconsistently disseminated, its messages are limited to mostly English and the City does not appear to be realizing the full value from NotifyLA.

During the 2017 La Tuna Fire – the worst to hit L.A. in half a century – hundreds of notifications, tweets and statements were disseminated. These were primarily sent by the LAFD and via elected officials; none via NotifyLA, which has the ability to reach a larger audience of Angelenos – notably those who might not be engaged on social media or watching television during an emergency.

Since 2014, just 35% of all NotifyLA notifications sent alerted the public to a large scale emergency. This missed the original intent of a system created to alert residents about large scale emergencies – and it has fallen short of what the public should expect from our City’s mass notification system.

There also has been inconsistency as to the publication of wireless alerts. While NotifyLA did not send alerts during the La Tuna Fire, it did advise residents about evacuation orders related to the Creek Fire several months later. EMD did so using a variety of methods except for the one with the largest reach: wireless alerts. Later that afternoon, it did use wireless emergency alerts to update residents about the evacuation orders.

We cannot take chances when it comes to public safety, which is why I am issuing a series of recommendations to strengthen our notification system.

  • NotifyLA should disseminate alerts for any large scale emergency already publicly communicated, directing Angelenos to the agency in command for more information.
  • Meanwhile, it’s imperative that EMD formalize its procedures within its department – and with LAPD and LAFD – for when to disseminate wireless emergency alerts, erring on the side of more information to ensure the widest possible audience during potentially dangerous situations.

Even when notifications are sent, they are inherently limited by few language offerings. L.A. residents speak more than 185 languages, yet NotifyLA alerts in just two – English and Spanish. Even its Spanish offerings are rare, accounting for just 21% of alerts since 2014.

  • EMD should provide translations into other commonly spoken languages in the City, such as Armenian, Korean, etc. Emergency notification systems within the County of Los Angeles and the Los Angeles Unified School District each support a minimum of five languages while New York City offers pre-scripted emergency alerts in 13 languages.

We noted in our review that EMD staff is not entirely pleased with Nixle, the platform used to send out NotifyLA alerts. Issues with geolocation and cost contribute to questions about the best value for taxpayers who ultimately pay and benefit from the City’s emergency alert system.

  • Angelenos deserve nothing but the best, especially when it comes to their safety. If the current system is not meeting our high standards, EMD should work to achieve better value.

The Emergency Management Department – and our police and fire departments – work around the clock to keep Los Angeles safe. But we are collectively falling short on providing an emergency notification system that should be more widely disseminated and accessible to more Angelenos. The City can do better and I am confident that working together, we can improve.

Respectfully submitted,

RON GALPERIN
Los Angeles Controller

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Executive Summary

All cities are vulnerable to both natural and man-made threats that can put peoples’ lives and safety at risk. In Los Angeles, potential hazards and disasters include earthquakes, fires, severe weather and flooding, excessive heat, landslides, active shooters, and terrorism. The City’s first responders (Police and Fire departments) are deployed to address imminent situations; the City’s Emergency Management Department (EMD) is charged with sending informational alerts to the public about necessary actions to take in those situations, such as evacuating or sheltering in place.

City information on emergencies is disseminated through various means including the press, public statements from city officials, social media, and websites. The City’s mass notification system, branded as “NotifyLA”, is an informational tool with the capability to send immediate, automated alerts to the public through landline phones (as recorded message), and cell phones (through text messaging) or computers (through email) to subscribers. NotifyLA is free to the public, and individuals are encouraged to sign up to receive alerts via text, email, or social media. While landline phones within the City are included in NotifyLA, it can also send Wireless Emergency Alerts (WEA) to all smartphones within a designated area, similar to “Amber Alert” messages that emit distinct ringtones and vibration patterns. Given its potential to reach a large audience of Angelenos at the same time, it is critical that the City utilize the NotifyLA system in the best way possible to inform people about necessary actions they should take to preserve life and safety.

Our review found that the City needs to improve how NotifyLA is used to disseminate timely emergency information to the public, and address issues to optimize the system to provide more value to both subscribers and City operating departments, as noted below.

Disseminating Useful Emergency Information to the Public

NotifyLA has been used inconsistently in communicating emergency information to the public. EMD sends alerts based on direction by incident commanders (to help comply with coordination protocols). We noted that NotifyLA was not used to send alerts related to the September 2017 La Tuna Canyon Fire, but it was used three months later for the Creek fire. EMD’s General Manager stated that he advised the incident commander to use NotifyLA for this emergency; however, the Los Angeles Fire Department (LAFD) chose other communication methods. Also, while EMD did not use the Wireless Emergency Alert capacity for an initial evacuation order for the Creek fire (Sylmar) area, it did use that functionality later in the day for an update on the same issue.

Public notifications through NotifyLA have generally been restricted to urgent emergency matters, which appears consistent with other cities’ practices relative to emergency management communications. EMD’s draft operating procedures1 indicate that strict protocols and governance measures have been implemented to ensure the system remains as effective as possible, which includes limiting the incidents/emergencies for which the system will be activated2, and only using the system when the public is being asked to take some action.

To support effective and consistent use of NotifyLA, EMD should formalize and distribute to all City Departments that use the system an updated Standard Operating Procedure that provides sufficient guidance on how and in what circumstances it should request an alert be sent by EMD. Internal protocols should also clarify what criteria should be used as a basis for EMD to coordinate messaging, to assure NotifyLA messaging aligns with City leaders’ expectations for the most effective use of a public emergency mass notification system.

The City should use Wireless Emergency Alerts (WEA) more consistently to deliver critical information that can minimize potential tragedies. While NotifyLA offers the City the ability to send notifications to a recipient’s cell, email, or landline phone, it can also opt to deliver those via WEA, which taps into the (federally-regulated) communication network. When and under what circumstances a jurisdiction initiates a WEA is at the local agency’s discretion, and there is debate among emergency management professionals about how often a WEA should be used. During the 2017 Santa Barbara fires, County officials sent thirteen WEAs over the course of the emergency because they did not want to take the chance that lives would be lost. In Sonoma County during the Tubbs fires, officials opted not to use WEA and dozens of people perished.

Since WEA serves as a precautionary measure to save lives and is capable of reaching the maximum number of people and devices, it would be of value to the public if the City used all of NotifyLA’s alert capabilities, including WEAs, when a significant disaster strikes.

To improve the dissemination of emergency information:

  • EMD and/or the LAPD’s Department Operations Center should be required to disseminate alerts via NotifyLA for any emergency that is communicated to the public by the City through other methods (official press release, public comments by public officials, City social media accounts, etc.). The Emergency Operations Board should approve, support and enforce this policy.

1 Still in DRAFT as of our review, but modeled / updated from the official protocols disseminated in April 2014, before NotifyLA was implemented; when such notifications were to be communicated through Alert LA County.

2 These include: Imminent Threat to Life or Property; Disaster Notifications; Evacuation Notices and/or Information; Public Health Emergencies; and Other notifications to a defined community, as approved and deemed significant by the EMD General Manager, Assistant General Manager, or Duty Officer.

  • EMD should formalize Standard Operating Procedures (SOP) for Activation of Public Emergency Notification Systems, and provide guidance and training to City departments on the importance of using NotifyLA to reach the public at large. Also, EMD should develop protocols for the consistent dissemination of messages as Wireless Emergency Alerts (WEAs).

Optimizing NotifyLA for the Public

Although U.S. Census data approximates that 46% of Los Angeles area population speak English less than “very well”, EMD primarily communicates NotifyLA emergency notifications in one language. NotifyLA data revealed that only 4 notifications sent by EMD since 2014 were translated into Spanish.3 Further, as the system translation feature is limited to just Spanish, EMD could not translate notifications into any of the other commonly spoken languages in the City, such as Chinese4, Armenian, Korean, Tagalog, or Vietnamese.

Los Angeles residents speak more than 185 languages, and tourists visit from all over the world; it is critical that the City provide important information through multilingual means to help ensure everyone has the opportunity to take safety measures when a disaster strikes. In 2016, the City of New York expanded its emergency notification program to support pre-scripted translations in 13 languages, including Arabic, Bengali, Chinese, French, Haitian Creole, Italian, Korean, Polish, Russian, Spanish, Urdu, and Yiddish. Expanding NotifyLA’s capability to deliver pre-scripted messages in other languages would better serve the City’s diverse population.

NotifyLA subscribers may not find value from signing up through text messaging, due to receiving unwanted non-emergency messages from other jurisdictions. NotifyLA is supported by the Nixle platform, which also offers services to the emergency management departments and first responders of several local governments. When a user signs up to receive text messages on their phone, the provided zip code determines which future notifications to send to the subscriber’s contact number. However, the subscriber may then unintentionally receive messaging initiated by other law enforcement agencies, such as the County Sheriff’s Department and other cities’ police departments, who may use the alert system to provide general public information, such as public information campaigns, street closures, or to solicit the public’s help in investigations.

While the City has been successful in increasing subscribers to NotifyLA, it is marketed as the City’s system to provide alerts about emergency and critical incidents. Given that subscribers are not provided with instructions on how to limit the type and source of messaging they receive, they may unsubscribe from NotifyLA altogether to avoid the excessive messaging. Moreover, subscribers may not see a benefit from subscribing to NotifyLA since the system automatically includes the capability to deliver messages to landlines in the City, or to all smartphones as WEAs.

3 Of the 41 non-test messages sent via NotifyLA, auditors were able to review message details for 19 notifications.

4 The US Census Bureau includes Cantonese, Mandarin, and other Chinese languages in its classification of “Chinese.”

To optimize NotifyLA for the public, EMD should:

  • Develop a plan including any needed funding to facilitate translations of emergency alerts into the City’s commonly spoken languages.
  • Refine its NotifyLA subscription campaign to demonstrate a clear value to potential subscribers.
  • Provide subscribers with step-by-step instructions on how to filter messages for subscribers to define notifications that are relevant to them.

Facilitating City Operations Through NotifyLA

City departments could better leverage NotifyLA for communications relative to the City’s Disaster Service Worker (DSW) Program.

As required by California law, all personnel employed by a city, county, state, or public district are automatically designated as disaster service workers.5 As part of the DSW program, EMD indicated that City employee duties may include assisting:

  • The Department Operations Center or the City’s Emergency Operations Center;
  • City departments with their response efforts;
  • or Nonprofit organizations in their response efforts.

When the Mayor issues an emergency proclamation and DSWs are activated, DSWs are expected to report for assignment as directed by their department management. City departments could leverage NotifyLA’s capabilities to call on personnel to serve the public and assist with an emergency response; however, it is up to each department’s emergency coordinator to determine whether, or how to use NotifyLA for their interdepartmental communication needs, including informing employees of their DSW responsibilities during an emergency.

The Controller has initiated a separate review of the City’s Disaster Service Worker Program, which will expand on these opportunities.

The City could benefit from a coordinated negotiating effort, including issuing a new RFP, and potentially utilizing one consolidated agreement with the current provider. Without a new Request for Proposal (RFP), the City may not be receiving the best pricing and services to meet its needs. The systems platform used for NotifyLA was procured years ago, and the current service agreement does not specify terms of service or how the City’s pricing or use is defined. The software provider has since been acquired by another company that provides an expanded product suite; in addition, technology and the needs of the City have changed over time. We noted both the Los Angeles World Airports (Airport) and the Harbor Department (Port) have service licensing agreements for an automated notification system with the same vendor. We noted that during 2017, the Airport and Port separately paid $97,000 and $23,000, respectively while EMD paid $235,000 for a one-year subscription to support NotifyLA. Other jurisdictions indicated their annual costs range from $34,000 to $80,000.

5 California Government Code Section 3100-3109.

While the underlying infrastructure and functionality of the systems appears similar, cost differences may be the result of neither the Airport, nor the Port using their systems for general public alerts, nor soliciting subscribers from members of the public. Other cities are smaller and two contacted cities indicated they use the vendor’s expanded product.

However, since the services are similar and provided by the same vendor, and the industry and related products have changed significantly since the original selection and pricing decisions were made, the City would benefit from coordinated negotiating effort, including issuing a new RFP, to obtain the best product, services and pricing for the system platform to support NotifyLA.

To facilitate City operations through NotifyLA:

  • EMD should work with the Airport and Port departments to coordinate negotiations and contracting efforts, to provide the City with the best service agreement for the best price.
  • EMD should work with stakeholders to develop specifications for a new Request for Proposal, and solicit competitive bids for the platform to support NotifyLA.

Conclusion

As a citywide public mass notification system, NotifyLA’s primary objective is to quickly deliver alert, warning and instructional messaging to City residents and businesses during disasters or large scale citywide events. The system also allows the City to send important information regarding incidents/emergencies in defined geographical areas, and facilitates emergency communication with employees. While the web-based platform used to support NotifyLA has sufficient functionality, the City should address the issues noted in this review to maximize its effectiveness and value.

  • The City should take a more consistent approach to using the system when an emergency event occurs, and use of Wireless Emergency Alerts when appropriate to increase the likelihood that the public will be aware of necessary actions to preserve life and safety.
  • To provide more value to the public, EMD should refine its subscription campaign to demonstrate the value for signing up for text and email notifications, and provide additional information to help subscribers set their desired message delivery settings. In addition, EMD should increase the availability of multiple languages, so that important messages are understood by the City’s non-English speaking residents and visitors.
  • The City should coordinate its negotiating efforts to obtain the best product and services to support its current needs for a mass notification system, at the best price and pursue issuing a new RFP.

Review of the Report

On July 12, 2018, a draft of this report was provided to EMD management. We met with Department management at an exit conference on July 19, 2018. EMD management generally agreed with the issues and recommendations and provided some clarifications. Additionally, we provided a draft of the report to the Chiefs of the Los Angeles Police and Fire Departments as Recommendation 2 is addressed to the Emergency Operations Board (EOB) in which they serve as Chair and Vice-Chair, respectively. We considered all views and comments as we finalized this report. EMD provided their formal response and action plan on August 10, 2018, which is included as Appendix II.

Based on our evaluation of EMD’s reported actions and implementation plan, we now consider seven recommendations as “In Progress” (Recommendations 1, 2, 3, 4, 5, 7, and 9) and three as “Not Yet Implemented” (Recommendations 6, 8, and 10). While EMD’s action plans generally meet the intent of the recommendations, further clarification is provided for Recommendations 1 and 7.  

EMD intends to revise its Standard Operating Procedures (SOP) to address Recommendation 1. As part of the action plan, EMD should also provide guidance and training to departments on the use of NotifyLA.

EMD’s response to Recommendation 7 is to enhance its social media and website coverage for potential subscribers but that funding would be needed for a campaign. The intent of the recommendation will be met through EMD’s current “campaign” efforts through its social media and website coverage; a paid marketing plan is not necessary.

We thank EMD staff and management for their time and cooperation during this review.

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Background

Description of NotifyLA

The Emergency Management Department (EMD) manages the City’s mass notification system, which is marketed as “NotifyLA.” EMD and LAPD disseminate NotifyLA messages to the public about emergency events and incidents. EMD messages may relate to:

  • Early Warnings
  • Disasters
  • Evacuations
  • Public Health
  • Public Safety of imminent or perceived threats to life or property

On-duty officers within EMD work with incident commanders (i.e., first responders) to determine who should receive a notification at the time it is written, and sends it to the general public, residents, businesses, other City employees, and subscribers of NotifyLA.

NotifyLA is meant to supplement preparedness efforts by disseminating alerts, which can also provide links to other informational sources with more specific and targeted information. There are a variety of methods to communicate with the public during an emergency, depending on the type and significance of the event. Generally, the lead first responder department (almost always Police or Fire) will determine the preferred method of sharing information, which can include media releases, social media and twitter, websites, live videos, etc., and efforts to engage the broader media to bring attention to the matter. First responders may also be deployed to provide an in-person, door-to-door notice, should a specific area experience a significant emergency.

Software Support / Hosting

NotifyLA is supported by a web-based platform called Nixle, a product of Everbridge, Inc. The system is hosted on the cloud and managed by the provider. This is beneficial because authorized users can access the system anywhere using any device that can connect to the internet, and there is no need for the City to maintain or update the software. Other jurisdictions we contacted also use a web-based platform for their notification systems, with the majority using an Everbridge product: Beverly Hills, Glendale, Culver City, Burbank and Pasadena; while Long Beach and LAUSD use a Blackboard product, and the County of Los Angeles uses CodeRed by Onsolve. Several emergency managers we spoke with consider the Everbridge Suite to be superior to the Nixle product, and some noted that Nixle is provided free of charge to local police departments.

Message Delivery

Notifications can be sent through the Nixle platform, to landline telephones, telecommunication devices for the deaf (TTD), and to subscribers’ cellphones and/or email and social media accounts. At the time we initiated this review (March 2018) there were approximately 1.7 million landline phone numbers included in the system, and approximately 215,000 additional subscribers.

When creating a message for dissemination, the Nixle system requires that it be classified as one of three types:

  • Alert messages are to be reserved for critically important information where loss of life and/or property is potentially imminent. Alert messages are time-sensitive and require residents to take immediate action (e.g., severe weather warning; gas leaks; wildfire; missing child; contagious disease outbreak, etc.)
  • Advisory messages are intended to communicate important, need-to-know information. Advisories are considered less time-critical than Alerts and require a heightened sense of awareness for residents (e.g., road closure/detour; severe weather watch; police activity; etc.)
  • Community messages are used to convey everyday local news, happenings and developments (e.g., event reminder; crime prevention tips; police blotter, etc.)

NotifyLA alerts are typically effected by EMD’s on-duty officers, in an effort to restrict Citygenerated notifications to urgent, emergency matters. If a critical life-safety situation arises or during EMD off duty hours, designated members of LAPD’s Communications Division can also initiate notifications directly; without EMD’s involvement. From 2014 through 2017, we noted that 41 messages (excluding “tests”) were sent through NotifyLA: 27 were classified as “Alert”, 12 as “Advisory” and two as “Community”. This appears consistent with other cities’ practices relative to emergency management communications: representatives from Beverly Hills; Glendale and Long Beach indicated they send fewer than 5 alerts per year, restricted to emergency notifications. We also noted that some cities’ police departments use Nixle’s messaging capabilities more extensively, as a social media outreach tool; however, an emergency manager at a neighboring jurisdiction stated Nixle was not effective for their intended use, emergency alerts.

The NotifyLA system also provides the City with the capability to send Wireless Emergency Alerts (WEA) as permitted by the federal government through the Integrated Public Alerts Warning System (IPAWS)6 to participating wireless carriers, which then push the alerts to mobile devices in the affected area. A WEA is a distinct notification that appears on the screen of the recipient’s mobile device as a text-like message. It is accompanied by a unique sound and vibration, which is particularly helpful to people with hearing or vision-related disabilities. WEA are transmitted to all smartphones within an approximate geo-location based on the position of cellular towers. Therefore, all WEA-capable mobile devices in that zone can receive the alert, even if they are roaming or visiting from another state. WEA covers only critical emergency situations, and consumers may receive only three types of alerts: Alerts issued by the President of the United States; Alerts involving imminent threats to safety or life; and Amber Alerts. To initiate a WEA, local jurisdictions must have an executed agreement with the Federal Emergency Management Agency, and designated individuals must be appropriately credentialed.

The Nixle platform used by NotifyLA, and similar systems used by other jurisdictions, can also be used for internal purposes; to disseminate messages to defined groups of employees or stakeholders and coordinate information sharing. Some departments (i.e., the City’s Airport, Port, and Recreation and Parks departments) use NotifyLA or another Everbridge product for their specific internal communication needs, and the cities of Beverly Hills, Glendale, and Long Beach also use their systems to contact employees for emergency callbacks.

6 In accordance with federal requirements established by partnership between the Federal Communications Commission (FCC), the Federal Emergency Management Agency (FEMA) and the wireless industry, the City of Los Angeles has an executed memorandum of agreement with FEMA that allows authorized users to initiate WEAs through the NotifyLA system, which are then sent through IPAWS.

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Observations & Recommendations

Section I: Disseminating Useful Emergency Information to the Public

A. The City has inconsistently used NotifyLA to provide timely information to the public.

EMD’s role in emergency notification is to coordinate critical messages from the City’s first responders (LAPD/LAFD) or the incident’s unified command of various jurisdictions to the public. As outlined in the City’s Emergency Public Information Annex, the incident commander is to determine what information will be made available to the public. EMD will then coordinate emergency notifications through NotifyLA only when requested and deemed necessary by public safety officials. EMD noted that this practice can prevent unintentional interference with the emergency response operations; however, it may also inadvertently withhold critical information from the public that could be reached through the City’s NotifyLA system.

On September 1, 2017, the largest wildfire to hit the City in over 50 years broke out in the La Tuna Canyon area of Sun Valley, burning more than 7,000 acres and resulting in the evacuation of more than 100 homes.7 On September 2, 2017, the Mayor issued an emergency proclamation, noting that the magnitude of the conditions exceeded normal local government services and requested aid from the State and Federal governments.8

Despite the gravity of the incident, the City did not use NotifyLA to alert the public about the fire or the evacuation orders, opting to pursue other avenues to communicate information, such as door-to-door notifications, the media, social media, and public statements from City officials. Although emergency on duty officers (EDOs) were following the City’s emergency public information protocols and complying with coordination responsibilities as described in the Administrative Code, these policies appear to be contrary to the original intent for obtaining a system to contact residents about emergencies, or what the public would expect from the City’s investment in a mass notification system.9 EMD’s General Manager stated that he advised the incident commander to use NotifyLA for this emergency; however, LAFD chose other communication methods.

NotifyLA data obtained from EMD revealed that from May 2014 to March 2018, 65% (75 of 116) of all generated notifications were classified as internal tests. The remaining 35% were notifications relative to active shooters, Emergency Operations Center (EOC) activations, fire and flood evacuation orders, and public health outreach.10 Generally, test messages are not delivered to the public and are typically meant to be used for internal and training purposes. While testing is necessary to simulate real-life scenarios and prepare EDOs to send notifications during an emergency, it appears the City missed an opportunity to do just that when the fire broke out in La Tuna Canyon.

7 Council File 17-1037 <http://clkrep.lacity.org/onlinedocs/2017/17-1037_rpt_EMD_11-02-2017.pdf>
8 Council File 17-1012 <http://clkrep.lacity.org/onlinedocs/2017/17-1012_rpt_MAYOR_09-05-2017.pdf>
9 Council Fie 08-1684: <http://clkrep.lacity.org/onlinedocs/2008/08-1684_mot_6-25-08.pdf>
10 EOC activations bring representatives from emergency responders to the Emergency Operations Center to coordinate field operations, meetings, and public information during an emergency.

Three months after the fire broke out, the City did use NotifyLA to deliver evacuation orders associated with the Creek Fire (in Sylmar); however, it did not use the system’s broader WEA capabilities, as discussed in the next section.

While the system allows the City to send out important community advisories (such as shelter locations; utility disruption; road closures), public notifications through NotifyLA have generally been restricted to urgent emergency matters, which appears consistent with other cities’ practices relative to emergency management communications. EMD’s draft operating procedures11 indicate that strict protocols and governance measures have been implemented to ensure the System remains as effective as possible. Primary among these is designating those incidents/emergencies for which the system will be activated, which is limited to:

  • Imminent Threat to Life or Property
  • Disaster Notifications
  • Evacuation Notices and/or Information
  • Public Health Emergencies
  • Other notifications to a defined community, as approved and deemed significant
    by the EMD General Manager, Assistant General Manager, or Duty Officer.

The draft protocols also state that the system will be used only when the public is being asked to take some action (e.g., evacuate, prepare to evacuate, shelter in place, boil tap water before drinking, etc.).

While EMD is responsible for training operating departments on these procedures, the prior (2014) policy indicated that the training and protocols be distributed to each Departments’ Emergency Management Coordinator and Public Information Officer, and included worksheets to be completed and forwarded to EMD for the basis of approving and scripting the alert. However, the current draft protocols are not as clear, stating “EMD recommends a minimum of four people be trained to use the NotifyLA system” and includes only a WEA worksheet.

To support effective and consistent use of NotifyLA, EMD should formalize and distribute to all City Departments an updated Protocol and Standard Operating Procedure (SOP) on the activation of public emergency mass notification systems. The SOP should provide sufficient guidance to Departments on how and in what circumstances it should request an alert be sent by EMD. Internal protocols should also clarify what criteria should be used as a basis for EMD’s approval, to assure NotifyLA messaging aligns with City leaders’ expectations for the most effective use of a public emergency mass notification system.

11 Still in DRAFT as of our review, but modeled / updated from the official protocols disseminated in April 2014, before NotifyLA was implemented; when such notifications were to be communicated through Alert LA County.

Because NotifyLA’s technology is geographically imprecise and messages are limited in length12, alerts may reach individuals beyond the boundaries of an emergency incident and cause confusion for people who do not need to take specific actions (i.e. evacuate, shelter in place). To address this risk, EMD could expand its use of general pre-scripted messages that direct the public to other sources of information for specific directives (like EMD/LAFD/LAPD’s websites and social media).

Recommendations:

  1. EMD should formalize Standard Operating Procedures (SOP) for Activation of Public Emergency Notification Systems, and provide guidance and training to City Departments on the importance of using NotifyLA to reach the public at large. TheSOP should include protocols for how Departments should request and/or direct EMD to send the notification as an alert, advisory, or community message.
  2. EMD and/or the LAPD’s Department Operations Center should be required to disseminate alerts via NotifyLA for any emergency that is communicated to the public by the City through other methods (official press release, public comments by public officials, City social media accounts, etc.). The Emergency Operations Board should approve, support and enforce this policy.
  3. EMD should expand its use of generic pre-scripted alerts to send to the public during an emergency, which direct recipients to more detailed information onEMD/LAFD/LAPD websites and social media.

B. The City should use Wireless Emergency Alerts (WEA) more consistently to deliver critical information that can minimize potential tragedies.

When the City issues an evacuation order due to a life-safety emergency, the public expects that the City would use all tools at its disposal to notify them of the necessary actions to take. Through NotifyLA’s WEA capability, the City can do just that. WEA are delivered to all WEA-enabled devices within a specified geographic location, emitting a noticeable sound and vibration to get the recipient’s attention. Delivering evacuation orders through this technology can help provide useful information to minimize and prevent deadly tragedies.

12 Text messaging in Nixle is limited to 138 characters and WEA messages are limited to 90 characters.

On the morning of December 5, 2017, the City issued several mandatory evacuation orders due to the Creek Fire.13 The City alerted the public through most NotifyLA delivery methods (email, landline calls, and text messages), except WEA.

Later that afternoon, EMD sent an update message regarding the Creek Fire using all available delivery methods, including WEA, informing the public that “Mandatory evacuations will remain in place until further notice.” While the delivery of the follow-up message conformed to reasonable expectations for the City’s use of a mass notification system, the initial morning evacuation orders did not.14

EMD noted that incident commanders may decide not to use WEA for an initial order to evacuate in order to minimize traffic congestion that could get in the way of first responders en route to the incident. EMD added that messages may reach individuals beyond the boundaries of an emergency incident, causing confusion for people that may not need to evacuate. While this may be a risk, there may also be an advantage to using WEA to get the public’s initial attention.

WEA Messages by Other Jurisdictions

In December 2017, the Los Angeles Times (LA Times) noted that Sonoma County officials expressed concerns about emergency notifications related to the Tubbs fires in Northern California.15 Sonoma County officials decided not to use the WEA system; instead opting to notify the public about evacuation orders through text messages and robocalls made to landline phone numbers. The LA Times also noted that only 50% of the landline calls were answered by either a live person or answering machine. The fire ultimately killed dozens of people.16

By comparison, Santa Barbara officials used the WEA system 13 times within one week to issue alerts, including evacuation orders. The Santa Barbara Emergency Manager told the LA Times that notifications probably went beyond those in immediate danger. Though this may have been justified as landline calls about the December Santa Barbara fires were answered by a live person or answering machine 15% to 55% of the time.

In the City of Los Angeles, NotifyLA data shows that since 2016, any time an evacuation order was disseminated to City of Los Angeles landline telephones, an average of 21% of the calls successfully reached a live recipient, when counting calls that reached an answering machine, the average completion rate increases to 32%. Although those automated calls were also accompanied by text messages and emails sent to NotifyLA subscribers, EMD could have leveraged WEA technology to reach broader segments of the public that may not have been watching news coverage, or been asleep.

13 The Creek fire area refers to vicinities of Sylmar.

14 EMD indicated that it tried to send a WEA; however, due to geo-targeting limitations a WEA could not be sent.

15 LA Times, December 2017 < http://www.latimes.com/local/lanow/la-me-fire-warnings-failure-20171229-story.html>

16 ABC News, October 2017 <https://abcnews.go.com/US/photos-neighborhood-destroyed-wildfire-santa-rosacalifornia/ story?id=50397309>

Despite differing opinions among Emergency Management experts about using WEAs, this messaging system may be the best option to minimize and/or prevent deadly tragedies like those experienced in Sonoma County. The recipients of such messages are more likely to be alerted and/or awakened by the distinct WEA sounds/vibrations than they would from traditional information methods. In addition, WEAs go to all cell phones that are currently present in a geographic region, not just residents with a landline, or active subscribers. To  address the risk that people who are unaffected by the emergency may take unnecessary actions, WEA messages could be crafted to provide a general alert, but also direct the public to other sources of information for specific directives (like EMD/LAFD/LAPD’s websites and social media).

Recommendation:

  1. EMD should develop protocols for the consistent dissemination of Wireless Emergency Alerts. These protocols should be submitted to the Emergency Operations Board for approval.

II. The Value of Optimizing NotifyLA for the Public

C. Census data noted that about 46% of Los Angeles area households17 spoke English less than “very well”; however, NotifyLA communicates emergency notifications in English, and only 21% of notices were also translated into Spanish. NotifyLA’s Nixle platform allows EMD to send notifications in English and Spanish, as the system provides an automated translation feature for Spanish only. However, EMD must proactively initiate opting to send a Spanish translated message to the public.

Based on NotifyLA data we reviewed, we were able to confirm that only 4 notifications sent by EMD since 2014 were translated into Spanish.18 Since the system does not support translations to any other language, no messages were disseminated in any other language. The system can theoretically send an alert in any language, if the author types the message in that intended language. Subscribers must also indicate their preferred language, for targeting messaging. Several jurisdictions we contacted noted that they do not rely on automated system translations; rather, they prefer staff translations and have set up initial generic messaging in additional languages, and use employee translators or separate contract.

EMD should consider adding other languages to its notifications, since Census Bureau data for 2009-2013 noted that 46% of the population in the Los Angeles-Long Beach- Anaheim Metropolitan area spoke English less than “very well”. According to census data, there are at least 185 languages spoken at home in the Los Angeles Metro area.19 In addition to Spanish, other commonly spoken languages included Chinese20, Armenian, Korean, Tagalog, and Vietnamese. The emergency notification systems of the County of Los Angeles and the Los Angeles Unified School District (LAUSD) support a minimum of five languages, including English, Spanish, Chinese (dialect unknown), Korean, and Russian. In 2016, New York City expanded its emergency notification system to offer multilingual messages, including prescripted alerts in thirteen different languages.21 Emergency management personnel in Beverly Hills set up initial messages in Farsi; Glendale indicated they were addressing needs for Armenian, Korean, and Tagalog speakers; and Long Beach is addressing translation needs for Spanish and Khmer. The City of Los Angeles could also better serve the public by using a system that provides translations, and/or allows for pre-scripted messages in multiple languages. Subscribers should then be able to define their preferred language for the alert or advisory notification.

17 Census data is based on the Los Angeles-Long Beach-Anaheim metropolitan area.

18 Auditors were able to review message details of 19 notifications. 19CensusinformationforLosAngelesMetroAreaasofOctober2015.<https://www.census.gov/newsroom/press-releases/2015/cb15-185.html>

20 The US Census Bureau includes Cantonese, Mandarin, and other Chinese languages in its classification of “Chinese.”

21 New York City Emergency Management supports Arabic, Bengali, Chinese,French,HaitianCreole,Italian,Korean,Polish,Russian,Spanish,Urdu,andYiddish<https://www1.nyc.gov/site/em/about/pressreleases/20160502_nycem-expands-notify-nyc-program-with-new-multilingual-messaging.p ge>

D. NotifyLA subscribers may not be aware that signing up through text messaging allows them to receive messages from other jurisdictions/law enforcement agencies, including potentially unwanted non-emergency messages.

Since NotifyLA uses the (shared) Nixle Platform, subscribers can receive text messages from other law enforcement agencies and jurisdictions within or around their defined zip code. Depending on how subscribers sign up for NotifyLA, they may also receive messages from other neighboring jurisdictions (e.g. Culver City police, Los Angeles Sheriff’s Department, etc.). Each jurisdiction defines how they utilize the Nixle platform for their specific needs; some use it to send messages for non-emergency social events, provide general information, to solicit the public’s assistance regarding law enforcement, and community awards/recognition announcements. As these may not be relevant or of interest to the City’s NotifyLA subscribers, some people unsubscribe.

EMD has pursued a goal to increase subscribers by 30,000 per year, which was far exceeded in FY 2017-1822. Through its website, EMD promotes NotifyLA as the City’s official notification system used to send messages notifying the public during emergencies and disasters, indicating “notifying the public when a disaster strikes might be the one and only safeguard the public can count on to save their lives and protect their property.” EMD engages the public to subscribe to NotifyLA through its website, text messaging campaigns, and Nixle’s website.

22 From July 1st through March 27th, EMD added 99,182 subscribers; totaling 215,000 as of March 27, 2018.

Regardless how an individual signs up as a subscriber, the registered zip code and phone number are used by Nixle to communicate messages to Nixle-registered mobile phone numbers in the area covered by the alert.23

There is no data on the number of individuals that have unsubscribed from NotifyLA. However, EMD acknowledged that people may opt out after receiving a preponderance of non-emergency messages; without knowing that they can actually limit those types of notifications. The subscriber would need to log onto Nixle.com, and change their message delivery settings.

To remedy potential confusion and the risk of subscribers opting out of NotifyLA when their experience is not aligned with their expectations, EMD should provide additional information on its website, and/or through a standardized initial message that directs subscribers to visit Nixle.com to review and set their desired message delivery settings.

Recommendations:

  1. EMD should refine its NotifyLA subscription campaign to demonstrate a clear value to potential subscribers.
  2. EMD should provide subscribers with step-by-step instructions on how to filter messages for subscribers to define notifications that are relevant to them.

23Nixle.com terms and conditions.<http://www.nixle.com/resident-terms-service/>

III. Facilitating City Operations through NotifyLA

E. City Departments could better leverage NotifyLA for communications relative to the City’s Disaster Service Worker Program.

Each City Department has assigned personnel to serve as their designated emergency management coordinators that are responsible for disaster preparedness, response, and recovery. During an emergency response and when the Disaster Service Worker (DSW) program is activated, coordinators can theoretically send out messages through NotifyLA to their department’s employees. Messages can provide Department-specific information that may be required, especially when or if employees are called upon to serve the public during a catastrophic emergency event. As required by California law, all personnel employed by a city, county, state, or public district are automatically designated as DSWs.24

As a DSW, City employees may be expected to carry on their normal duties or to perform work completely outside their normal day-to-day responsibilities. A DSW may be assigned and trained to:

  • Perform a specific job in a Department Operations Center or the City’s Emergency Operations Center, or
  • Assist any City department with their response efforts, or
  • Assist a nonprofit organization in their response efforts.

When disaster strikes and the Mayor makes an emergency proclamation, DSWs are expected to follow their department’s reporting instructions, and ought to be prepared for any assignment. City departments could leverage NotifyLA’s capabilities to call on personnel to serve the public and assist with an emergency response. At this time, it is unknown how many City employees are registered within NotifyLA for that purpose, since it is up to each department’s emergency coordinator to determine whether to use NotifyLA for their interdepartmental communication needs, including informing employees of their DSW responsibilities. For it to be effective, departmental coordinators would also be expected to ensure their respective employees’ contact information is in the system, and to keep that information current.

This topic will be further assessed in a separate review initiated by the City Controller that focuses on the City’s Disaster Service Worker Program.

24 California Government Code Section 3100-3109.

F. In the short term, the City could benefit from a coordinated negotiating effort and potentially utilize one consolidated agreement with the current vendor. However, without a new Request for Proposal (RFP), the City may not be receiving the best pricing and services to meet its needs.

In 2009, the City was awarded a federal grant through the Department of Justice’s Community Oriented Policing Services (COPS) Technology Program, for $500,000 to develop a citywide emergency mass notification system. The Los Angeles Police Department administered the grant award, and worked with the City’s Information Technology Agency (ITA); the Fire Department, and EMD to develop technical specifications for the system, and ultimately selected the Nixle platform for NotifyLA.

Since the expiration of the COPS grant, EMD has paid approximately $235,000 annually for a continued subscription to Nixle. These costs are paid through the City’s Emergency Operations Fund and represent a significant portion (33%) of its annual budget. The ongoing subscription is effectuated through an existing commodities contract with Public Sector Insight, a cooperative purchasing agreement administered by the General Services Department that allows the City to procure technology products and software solutions at the vendor’s list price, less discounts. However, EMD’s service agreement had no details regarding the specific pricing methodology, or even the general parameters for the system use (reference is made to a “Quote”, which was not available).

Nixle was selected almost a decade ago, and it has since been acquired by a competitor (Everbridge Inc.) which is maintaining Nixle as a separate product line and has indicated in public documents that it intends to “increase our customer base and upsell and crosssell additional and new applications to our existing customers”.

During this review, we also noted that the Los Angeles World Airports (Airport) and the Harbor Department (Port) have their own notification systems to meet their unique needs for communicating with employees and stakeholders. Both departments made individual payments to Everbridge, Inc., but neither of the two departments used Public Sector Insight to pay for Everbridge services.

Three City departments paid the following for the right to a one-year subscription for an Everbridge product during calendar year 2017:

  • Airport paid a total of $97,000 to Everbridge
  • $82,000 specifically for the subscription and
  • $15,000 for consulting services Port paid a total of $23,000 to Everbridge, and
  • EMD paid $235,000 to a third-party (Public Sector Insight, Inc.) for a license to use Nixle, which is now owned by Everbridge.

Other cities we contacted that also use an Everbridge product reported their annual costs of $34,000 (Beverly Hills); $70,000 (Burbank); and $80,000 (Glendale).

Airport and Port representatives indicated that they have different agreements and related payments for an Everbridge product because they have different needs. For example, Airport’s potential notification recipients include approximately 40,000 badged personnel at LAX, such as employees, contractors, federal agents, and airline/terminal staff and lessees. Targeted messaging to those individuals can be for site-specific emergencies such as terror alerts, or general informative non-critical events, such as traffic issues and lane closures. The Port uses the system to send notifications to Port Police, terminal occupants, and the U.S. Coast Guard. The system is used routinely to disseminate messages relative to the Port Chief’s daily briefing, issues affecting terminal tenants, overtime, movie set detail, traffic, and hazmat issues.

Neither the Airport nor the Port uses the system to alert members of the public, nor encourages the public to subscribe to their system. This may explain why Airport and Port paid far less than EMD for the right to use an Everbridge product, in addition to the fact that the Nixle system license for NotifyLA was not directly procured from the software company.

Regardless of what may contribute to the pricing differences, EMD may benefit from collectively negotiating with the vendor, in conjunction with the Airport and Port, in order to achieve the best service agreement for the best pricing, for the City.

The City has used the same mass notification system since 2009, even though the system functionality and the City’s needs have changed. Technology has improved and mass notification systems and services have evolved. The City should pursue developing a new Request for Proposals (RFP) based on its current and specific needs for a mass notification system. EMD should coordinate with other departments to develop specifications and select the best product for the best pricing.

Recommendations:

  1. EMD should work with the Airport and Port departments to coordinate negotiations and contracting efforts, to provide the City with the best service agreement for the best price.
  2. EMD should work with stakeholders to develop specifications for a new Request for Proposal, and solicit competitive bids for the platform to support NotifyLA.

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