In case Iraq Fails, A Contingency Plan

The Government of Iraq appears weaker and less capable each passing month and the prospects for its failure, and therefore the failure of American policy, should be examined along with contingency plans in case it does.

One potential solution that I've been mulling over basically boils down to "picking sides."  In essence, at some point we would cease being a pseudo neutral player in Iraq and choose a group or faction to explicitly support above all others.  Similar to what we did many times in South America, we'd feed this group weapons and training and help it dominate adversaries and either crush or force them to negotiate on favorable terms.  This could be done with little actual American military power, provided preparations are made in advance.  This course of action has the potential to give us a strong and reliable proxy to help protect our interests in the region and Iraq should the current government fail.

The downsides are, however, many.  Although I see this course of action taking place in the context of an obvious or imminent demise of the Iraqi government, it would still be viewed as a complete and blatantly hypocritical reversal of our policy of “promoting Democracy” in the Middle East.  The consequential damage to American prestige and influence must be weighed carefully. Additionally, there are ethical issues, obviously, and they would be exacerbated by ubiquitous media coverage that did not exist in places like El Salvador and Chile.  Insurgent warfare is an ugly business and if America supports a particular faction then many will view the US as culpable in whatever crimes that faction will inevitably commit, leading to reduced domestic US and international support among other negative consequences.  The worst possible consequence is our proxy might lose to a competing faction. This eventuality would not only diminish our influence throughout the region and increase the power and prestige of our enemies, but could necessitate another military intervention by the US itself. There are other negative consequences as well, mostly hidden, that we must try to take into account before formulating this type of contingency policy.

A vital question becomes, who do we support and pick as our proxy force?  At first the Kurds may appear to be the obvious choice, but they bring several significant downsides in addition to those discussed above.  First, there is the danger they may be more interested in using us to create a greater Kurdistan which includes parts of Turkey and Iran.  Our ally Turkey would be livid and promotion of the Kurds as the dominant group would ensure both Turkey and Iran would intervene to prevent Kurd adventurism.  Second, the Kurds have carved out their own bit of autonomy in the north and their ability and willingness to seize and control Arab Iraqi centers of gravity (like Baghdad) in the central and southern portions of the country are suspect at best.  One thing that Iraqi Arab Shia’s and Sunni’s can agree on is that they would never live under Kurdish rule.  So, overall, it’s better to leave the Kurds to prosper in limited autonomy and institutionalize the existing condition of a limited de facto Kurdish state.

A second option is to support a moderate Shia group or tribe from central Iraq.  Unfortunately, no group that I know of has an adequate base of power, but more importantly, a charismatic and dynamic leader with a penchant for dictatorial power.  I have admittedly spent little time on this area of research, so such a unique person, able to rise and control a major moderate group or coalition, may exist.  A moderate Shia dictatorship would assuage the Iranians somewhat, since they are more interested in a friendly stable neighbor in Iraq than in molding it into Iran’s image of Islamic revolution.  Still, given the wide range of Shia groups and the dominance of anti-American elements like Sadr, it’s difficult to find an adequate Shia proxy group.  We must keep in mind though, that power is relative and marginal groups like Tikriti Baathists and Bolsheviks have risen from obscurity to rule nations and empires.  For this reason, we should keep an eye on the Shia community and look for leaders and groups with the potential and interest in furthering American goals as well as their own.

My final option, which I consider the best and most likely, is a US-sponsored Iraqi military coup.  This is an eventuality we could start working toward now, since our position as the primary trainer and supplier of Iraqi military and police forces gives us an exceptional ability to work toward building and developing the necessary force and, more importantly, leadership, to stage a coup and deal with the consequences.  The top leadership would be very important, as a competent, charismatic and politically astute (as well as secular or moderately religious) person would be required to suppress sectarian divisions in the armed force he controls.  Pakistan’s Musharraf would be a good model, or perhaps someone like General Hamdami from Saddam’s old Army. 

A military coup model may be the best option we have for a few reasons.  First, work on building a professional Army needed for a successful coup does not mean we need to immediately give up hope on our current policy of democratization.  In this regard the military coup option becomes the best from a contingency-planning standpoint because the current Iraqi government will also need a capable military to succeed if it hopes to unite the country and defend its borders.  However, if the government does fail, by developing a pro-American military leadership and a well supplied and adequately trained force the military could step in and take over. Second, a military coup could make a potential (and likely) civil war shorter because the military should have an advantage in equipment, training and organization.  Third, since the military is already part of the government, it would probably be easier to gain international recognition for it than someone like Sadr or a fanatical religious organization like the Taliban in Afghanistan.

The primary problem is that a successful military coup would require both a core of competent leadership combined with an adequate and loyal force.  As it stands now, such a force does not exist, but it could with proper vetting and training, especially if we start now.

Whoever is chosen, the result could be several years, at least, of bloody civil war and the end of any hope for democracy in Iraq through the medium term.  Even so, a shorter, more violent and one-sided civil war may be preferable in the long run to an Afghan-style civil war that consumes generations and destroys all political and social institutions above the tribal level.  This brings us back to the ethical issue again – Overall, I believe a short, bloody civil war instigated and guided partly through American action is ethically preferable to the costs of inaction, whose poster-children are Afghanistan and Rwanda.  As unpalatable as it might be, we may eventually be forced by circumstance to choose sides and pick proxy to defend our interests and those of our allies.  We need to prepare for this contingency now.

Iraq and Terrorism NIE Leaked

The NYT is reporting tomorrow  (HT: RWN) on a recent National Intelligence Estimate (NIE) detailing the current state of international terrorist movements. Part of report concludes that the increase in Islamic terrorism is partly due to the ongoing insurgency in Iraq, which has become the new global training ground for terrorists.   The NYT piece says, in part:

The classified National Intelligence Estimate attributes a more direct role to the Iraq war in fueling radicalism than that presented either in recent White House documents or in a report released Wednesday by the House Intelligence Committee, according to several officials in Washington involved in preparing the assessment or who have read the final document.

The intelligence estimate, completed in April, is the first formal appraisal of global terrorism by United States intelligence agencies since the Iraq war began, and represents a consensus view of the 16 disparate spy services inside government. Titled “Trends in Global Terrorism: Implications for the United States,’’ it asserts that Islamic radicalism, rather than being in retreat, has metastasized and spread across the globe.

An opening section of the report, “Indicators of the Spread of the Global Jihadist Movement,” cites the Iraq war as a reason for the diffusion of jihad ideology.

The report “says that the Iraq war has made the overall terrorism problem worse,” said one American intelligence official.

The leak of this particular NIE will cause a predictable firestorm of partisan attacks by both the right and left, who will largely ignore lessons and judgments it contains in favor of election year politiking.

I'll edit this post with more information and commentary in the morning.

Beslan Anniversary

Today is the 2nd anniversary of the Beslan School Massacre.  Michelle Malkin has a good round up of stories.  To me, Beslan eclipses all other terrorist acts, including 9/11.  The deliberate targeting of children is, in my mind, the lowest of the low in human existence.  As a father, Beslan is a very powerful reminder of the depravity our enemies are capable of.

There is much misinformation on Beslan and what happened in the media.  I highly recommend this long article in Esquire which is an excellent overview of the tragedy.

Nasrallah's Crocodile Tears

Hezbollah leader Hassan Nasrallah today announced:

"We did not believe, even by one percent, that the captive operation would result in such a wide-scale war, as such a war did not take place in the history of wars. Had we known that the captive operation would result in such a war we would not have carried it out at all."

Apparently, his tone was "apologetic." He also said:

"Resistance will continue to be a tool for the army. There won't be a problem with UNIFIL so long as its mission won't be to disarm Hizbullah."

Hope the French have fun attempting to implement 1701!

(HT: TMV)

At first glance, this admission would appear to confirm that Israel significantly damaged Hezbollah, and Israel's invasion was a partial success.  However, Nasrallah's motivations for this admission are likely far different.  After an assessment of damage to civilian areas under Hezbollah control, Nasrallah is likely displaying this rare loss of face to serve two purposes.

First, and most importantly,  Nasrallah must realize there are elements in Lebanon that blame Hezbollah for bringing the wrath of Israel down on them - his statement is designed to counter that.  By showing regret and stating they didn't expect the Israeli response, he's attempting to assuage the blame centered on Hezbollah and focus it back on Israel.

Secondly, Nasrallah's contrition is designed to reinforce the perception in Lebanon, the Muslim world and the international community that Israel's invasion was a grossly disproportionate use of force.  Combined with other information operations, like the Ambulance hoax, it's designed to keep the focus on Israel and not Hezbollah.

Face is always important in the Arab world, and it is not given up easily.  In this case, though, it serves Hezbollah's purposes very well.

Recent Comments

I've had the opportunity recently to comment extensively on other blogs I'm reading. As I said in my last post, I'm better at counterpoint than point. Here are some highlights from this past week:

Right-Wing Nuthouse - I've been reading Rick Moran's blog for quite a while now and am a frequent commenter there.  I like his writing style, which is much better than mine, and although I don't always agree with his conclusions and observations, he usually has something interesting to say.

Rick wrote an interesting piece on the continuing bad relationship between intelligence and the White House. I got into an extended debate with another commenter, probably against my better judgment, on Iraq-AQ ties and the Iraq Survey Group.  Some people apparently continue to believe that Iraq actually had the WMD stockpiles we predicted and that the ISG was either too stupid or politically motivated to find the truth.  I don't understand this continuing perception, especially considering we've captured almost all the principal actors in the regime, including Saddam and Chemical Ali.  As many have rightly pointed out, there are many documents and other material that haven't been examined, but people seem to assume that the government has dropped the ISG work completely.  That is simply not the case.

My basic argument in regard to infighting between the CIA and the White House is that the relationship between policy and intelligence is flawed and broken.  In the current environment, with the threats we face, this broken relationship, more than anything else, is hurting our ability to identify and assess threats. Read my comments at Rick's blog, especially 11, 15, and 21, for more information on this as well as examples (sorry, I can't link directly to a comment on his blog).

Related to the problems of intelligence today is a fantastic report which exposes the non-structural and non-political problems of the intelligence community.  In essence, it addresses a huge problem in a growing intelligence apparatus - recruiting people with the skills, knowledge and mindset needed to succeed at the very difficult job of intelligence analysis.  It also rightly castigates the IC for it's focus on current intelligence as opposed to predictive analysis.  Anyone interested in intelligence problems in the US should read this fascinating report.

In another RWN post, this one on the UN, I make some general comments on how Superpower status affects our relationship with the UN and international community.  Then I digress in response to comments on the changing nature of warfare with this:

In the cold war, our primary military problem was having enough firepower to defeat the large numbers of Soviet personnel and equipment. Finding and fixing targets were not the problem (it’s not hard to locate a Soviet tank division), destroying them was. Today, the situation is turned on its head. We have more firepower than we know what to do with, but we’re unable to find and fix targets. The military is adjusting to this new reality as quickly as the bureaucracy and Congress will allow by fielding more reconnaissance and developing intelligence to queue those recon and surveillance platforms to look at the right places at the right times. Such transformation is slow, though, because it’s not just about equipment, but also training, personnel and especially people’s mindsets and preconceptions.

Rick's post also brought up a very interesting point:

There may have been a time in the bi-polar world created by the rivalry between the USA and USSR when the UN served a purpose. In this one instance, it was indeed better to pretend that what the world body did mattered, that the talking-shooting scenario was important to the continued existence of life on the planet. The alternative was unthinkable.

But that was when both superpowers recognized the efficacy of the UN fig leaf. They could climb down from confrontation without loss of prestige or face. In this case, it was mutually assured pretending that kept the peace and prevented the missiles from flying.

Finally, through some comment trails, I discovered The Glittering Eye.  So far, I like the blog quite a bit, and am participating in two discussions regarding Iran and military options.  My basic arguments here are that people who advocate attacking Iran have not thought through the consequences of doing so, and assume our military capabilities are greater than they are.  With regard to the Iranian nuclear program, I believe there is significant cause for concern, but I'm disturbed at the seemingly increasing numbers of people who believe with absolute certainty that Iran is "months" way from a nuclear weapon and that they will use it or give it to terrorists once they do.  In my humble opinion, I don't think many of these well-meaning individuals are thinking critically with regard to the evidence of Iran's program and intent.  Dave Schuler, the blog's author, seems to recognize this, though, like everyone in the blogosphere, his commenters don't. 

I do believe Iran want's the capability to build a bomb, but not necessarily the bomb itself.  A theory I've been batting around lately is that Iran wants basically what Japan has - a very well developed NPT compatible civilian infrastructure that would let them weaponize in a very short period of time. This theory is not perfect, but I think it's a valid potential alternative that should be looked into more closely (in addition to others).

After reading some of the The Glimmering Eye's historic posts, I can definitely recommend this blog.  It shows a level of analysis that is missing in many blogs today.  The author pointed me to this post on possible options regarding Iran which is well written and argued, although I think a few options were missed.

Update:  There seems to be some kind of problem with the spam filter at "The Glimmering Eye."  All of my comments there are currently missing.  Unfortunately, I there doesn't seem to be an email link to Dave.  If I don't see them reappear I'll send a quick note to his whois address to see if he can recover them.

Blog Silence

There has been an extended period of dead air here, but that's not much of a concern to me since virtually no one visits this site.  My excuse is that I was out of town for over a month and I've also slowly come to realize that I'm much better at commenting on other blogs than maintaining my own.  I realize that I think, work and write better when responding to others' arguments.

So, in the future, posts here will likely consist of some of my extended comments, fleshed out with context so they're readable.  I may also start maintaining links here to all my comments.  This is as much for me as anyone, since I frequently need to reference back to a comment I previously wrote. If anyone knows a way to automate this, I'd really appreciate an email.

Although I would like to blog more consistently, certain legal constrictions along with my busy life and my aformentioned predeliction prevents me from keeping up with the Jones'.

As always, thanks to those of you that do occasionally drop by!

Ignorance and the Media

Rick Moran over at RightWingNuthouse wrote another thought-provoking article on the need for more introspection in the media.  I couldn’t agree more with his description and analysis of the problem.  The most important connection he makes is the conflict between fluff stories that increase viewership and stories of national importance.  He says, in part:

The latest on a celebrity trial or the search for an unfortunate missing girl is a godsend to cable news because it keeps those eyeballs trained on their coverage of these stories long enough to build viewership, allowing them to both sell more advertising and charge more for the privilege....This kind of thing is no secret which is why the lack of introspection about this form of “journalism” is so disturbing.

Bingo.

Look at the most popular shows on cable news.  None of them are news programs.  They are all opinion shows by hosts with little to no journalism experience.  Shows like Hannity and Colmes deliver nothing of value to any debate since they largely consist of hardened partisans yelling their positions.  People who watch these shows are not looking for a reasoned debate on the topic.  I would genuinely be interested in a survey of this program’s viewers to find out why they watch and if their opinions are significantly challenged. After watching Hannity and Colmes and similar shows I don’t see how anyone could come away more informed on an issue.  There are exceptions of course, but they are few and far between. Some of the stuff Bill O'reilly has done I really respect.  I don't know anyone else on TV with the exception of John Walsh who covers the important story of exploited children.

Another problem is context that is given on news stories.  For a typical story on a 24 hour news show there is a short “reporting of the facts” segment sometimes followed by “analysis” from some pundit.  Typically, this pundits’ expertise is in politics, not the matter at hand.  I do occasionally see retired Generals who comment on an Iraq war story, but often it’s someone like Bill Kristol who can really digest the political angle of the story, but doesn’t fully understand the military aspects.  This is not to belittle Mr. Kristol or any of the other political pundits (except maybe Fred Barnes who has said some of the stupidest comments I’ve ever heard come from a TV), but is he really qualified to digest the military aspects of a story into a 30 second blurb?  Often I find they get it wrong.  Even the Generals get it wrong.  People in the media seem to believe that people of flag rank are universal military experts.  I’ve seem some particularly dumb comments from Air Force Generals talking about ground and special operations.  Most Air Force Generals don’t have a clue about ground combat, much less the operational details involved.   So I find it troubling that the “analysis” portion of these news stories are typically delivered with only a single, largely ignorant and often unbalanced viewpoint from someone who is not an expert on the subject.  The public is greatly disserved by this approach to the news.

I don't blame journalists personally for the failings of the news.  After all, it's not individual journalists, but editors and producers who are really in control of news content.  They are the people that decide what gets published and televised.  As Rick indicated in his post, they have to keep viewer ship in mind and, sadly, Americans, as a rule, do not have the intellectual interest or critical thinking ability to explore important subjects in depth.  This is one reason that I've always liked the News Hour with Jim Lehrer on PBS.  They actually spend more than 2 minutes on a topic and the debate is almost always fair, reasoned, and honest.  Instead of firebrand pundits like Ann Coulter, they invite experts from different viewpoints to debate the topic at hand in a civil fashion.  Of course, this makes for boring TV, which is why 99.9% of American's don't watch it.  PBS often gets accused of liberal bias, but I don’t think that extends to the News Hour which makes a genuine effort to bring representatives from all sides of a topic.  I think that is a primary reason why News Hour journalists are those most often selected to run Presidential debates.  Because PBS does not have to worry about increasing advertising revenue, they can concentrate on true journalism.  It’s one of the last bastions of true and honest journalism left.

Where does the “new media” fit into this question? Talk Radio and Internet media largely fill niches in the media landscape. One problem with the new “niche” media is that people look for and get "news" that supports their own preconceived notions and biases.  They never have to hear a critically reasoned argument or even an opposing point of view.  I think this phenomenon, along with a decline in critical thinking skills, has contributed significantly to the polarization of American society.  There is no way to legally or morally force people to diversify their information sources, even if such force were desirable. Were it possible, I seriously doubt that many people would read the Daily Kos and Powerline and then analyze both sides before forming an opinion.  I suspect, though I have no empirical data, that the majority of Daily Kos and Powerline readers are simply returning for more kool-aid.  I see this becoming more of an issue as the new media grows in depth and influence.  With so many sources of information, critical thinking skills are more necessary than ever, but they seem to be on the decline - or perhaps they were never strong to begin with.

A larger and very dangerous issue we face is the effect of this phenomenon in other parts of the world, particularly the third world.  Despite the lack of critical thinking skills in the American population the situation is much worse in less educated parts of the world, particularly in areas where children are indoctrinated from a young age.  Graduates of Madrassas and other religious schools in the third world receive the opposite of critical thinking skills.  It’s hard to imagine that the masses of poorly educated people in the third world will be able to distinguish fact from fiction or news from propaganda in any meaningful way.  We see evidence of this already with polls that show a majority of people in the Arab world believe the Isrealis were behind 9/11.  As the new media grows in the third world and access to media of all types becomes easily available to even the most poor, I can only predict that profound ignorance and delusion will grow to new levels.  The effect on our interests and foreign policy will likely be enormous.  Third world governments will increasingly be less able to control their populations and the opportunities for radical groups who’ve groomed the opinions of the ignorant to take power by popular vote or force is a significant problem we will face in the future.

I don't know how to solve the problem, but I think it ultimately is the responsibility of individuals.  I feel it's a huge crisis that so many remain willfully ignorant on important issues and refuse to think critically when presented with “facts” and analysis.  News organizations, in the highly competitive world we live in, will have to cede to the demands of their viewers no matter how shallow and trite they are.   So the question becomes, how can people be convinced to take more interest in stories and issues of real consequence, especially long-term consequence?  I don’t have a definitive answer except to do my small part and raise my kids to be independent and critical thinkers.  I hope you will do the same.

Left and Right both wrong on Zarqawi

Many other blogs are talking about the recent hit that took out AMZ, otherwise known as Abu Musab Al-Zarqawi, so I’ll add my two cents.

Bloggers on the both the right and left wings are predictable in their posts about AMZ’s death.  The righty blogs are gleeful and point to it as evidence that “progress” is being made, and that we are “winning.”  The lefty blogs, reluctant to give their nemesis, Bush, any credit, typically attempt to cast AMZ’s death as a minor incident that won’t stop further violence.  Of course, there is moonbattery on both sides, particularly from the left, but I’ll leave those opinions out of the discussion. I would argue that there is some truth in what both the left and right are saying, but, as usual, they miss the larger picture.  Let me explain further:

It is likely that killing Zarqawi will not have a huge effect on the level of violence in Iraq beyond a short lull while Al Qaeda in Iraq (AQI) replaces him.  AMZ has been increasingly unable to conduct the spectacular mass-casualty attacks he is known for and has instead been limited to the kidnapping/execution attacks we've seen in the past few months.  Operationally and logistically, it’s much easier and less complicated to commit acts of mass kidnapping and murder than suicide vehicle bombings. Our operations and security measures had somewhat limited his ability to operate as he pleased, but the bigger problem for his organization was the increasing power and influence of Iraqi Sunni and Shia militias.  While his mass-casualty attacks did generate some ethnic and religious hatred as well as increased chaos and fear in the country, they also isolated and alienated him from much of the Iraqi populace – even some of the more radical Sunni elements. In an effort to recast his organization, he brought in Iraqis and relied less on imported foreign fighters and Jihadists.  I suspect that one of the newer Iraqi leaders is at the root of his downfall.  Foreign fighters are generally more reliable and loyal, especially when attacking civilian targets. The Iraqi Sunni militias are probably happy to be rid of AMZ, as he was seen as both a threat and an alienating force from the Sunni base of support. As Sunni support for AMZ started to break down, he was pressed into a tighter geographical area and his organization could no longer operate as freely in Sunni areas as it once did.  Taken together, all these factors reduced AMZ’s military capability as evidenced by AQI’s declined over the last several months.  So, in the context of reducing violence, his death will likely have minimal direct effect.

I suspect that the 17 raids conducted immediately after the attack will have a greater long-term positive effect for Iraq and the coalition by capturing personnel and gaining actionable intelligence.  This appears to be happening now, as follow-on raids have already been conducted based on intelligence gained from the first 17.  An important point that most prognosticators overlook is that insurgencies are never defeated by killing personnel – even key personnel like AMZ.  They are primarily defeated by denying them access to safe havens and support in the local population and by denying and disrupting their operations.  The raids that occurred before AMZ’s death was public knowledge probably resulted in a significant disruption of AQI’s operations, at least in the short term.  It is likely that the Administration and those on the right will claim any decrease was caused by killing AMZ, but they would be wrong.

Commentators on both the right and left and also the media have wrongly focused attention on how AMZ’s death will affect the level of violence while ignoring other aspects of this victory. Even if AMZ’s death has no effect on actual AQI operations, it is still probably one of the most important morale victories for the US and Iraqi.  The morale of fighting forces, people and nations is always critically important – probably more important than actual fighting ability in fact.  The continuous and brutal level of violence in Iraq certainly saps the morale of the Iraqi people, Army and Police forces, to say nothing of US troops. Fighting forces, both US and Iraqi, are ineffective without morale and these kinds of victories help boost and sustain them.  There are many examples of similar “morale” victories throughout history.  One wartime incident that comes to mind for comparison is the Doolittle raid in WWII.  Militarily, the raid did not have much effect, although it did keep some aircraft out of the early stages of the war by causing the Japanese to deploy them to the home islands.  The raid was a tremendous victory for the morale of the allies, however; especially the United States people and its fighting forces.  That victory of morale was just as important as a victory on the battlefield.

So the right and left each have part of the story right, as is usually the case.

Unknown Heroes

I thought I would take this Memorial Day to remember the hundreds, if not thousands of unknown heroes whose contributions are lost to history.  The brutality, chaos and destruction of war sometimes results in the loss of whole units of fine Soldiers, Sailors, Airmen and Marines, and undoubtedly heroic acts have gone unchronicled as a result.  Who can say what acts of heroism some of these fine fighting men and women performed since there was no one left alive to bear witness them?  How many more Medal of Honor winners might we have if only we knew the lost history of their heroic acts?

So today I honor those lost heroes in American history and all the sacrifices of our fighting forces and the hundreds of thousands who’ve given their lives over the history of this nation.  We owe each and every one of them a great debt.

Fran's Fire Safety Inspection Clean

This post is a followup to Proof That Hilton Lied.

As I mentioned in my previous post, the letter that Hilton VP Marc A. Grossman sent to Leslie's Omnibus claimed that Fran's had "numerous health and fire safety violations" in the restaurant. Fran's had a clean bill of health from the DC Department of Health.  Anyone can review their restaurant inspection records online here.  To summarize, Fran's has never had a negative health inspection from the city.

Earlier this week, I submitted a FOIA request to the DC Fire and Emergency Management Services (FEMS) division to get copies of any fire safety inspections at Fran's.  When I spoke with one of the inspectors, he indicated they only keep records for about 3 years.

Today, I was faxed the reply:

Frans_inspection1

The only time in the past 4 years that Fran's was inspected was on October 17, 2002 when the whole Hilton building was inspected.  The entire building was "in compliance" at that time.

So it appears that the other half of Marc Grossman's claims are false, at least in regard to compliance with city health and fire safety requirements.  It's certainly possible that the Hilton chain has it's own requirements that are more stringent.  I have no idea what those could be since the city's health and fire codes are pretty tough.  One could claim that since the inspection report is over 3 years old, Fran's might have had violations in the meantime.  That's possible, but if so, why didn't anyone call FEMS to report it?  There haven't been any inspections of the building since late 2002.  I think the evidence would be more conclusive if the report were recent, but frankly Hilton doesn't have a good track record of honesty when it comes to Fran's.

So, unless Hilton produces some documentary evidence, I'm raising the BS flag on their claims.

Thanks to Mudville Gazette for the open post and support to Fran's.