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Running Campus Safety on an Island — What the Clery Act Doesn't Prepare You For

ISPI Perspective Campus Safety & Institutional Security 2026-05-18

Direct experience administering Clery Act compliance, Title IX coordination, and campus security on an island campus reveals gaps in federal guidance that no mainland institution faces.

WP
Warren Pulley
Founder & Executive Director — Island Security Policy Institute
BTAM-certified threat assessment practitioner with 2,400+ documented real-world assessments. 40 years of verified operational experience across U.S. Air Force nuclear security, LAPD, U.S. Embassy Baghdad diplomatic security, FEMA emergency management, and campus safety administration.

The Clery Act requires universities to publish annual security reports, maintain crime logs, issue timely warnings, and conduct emergency response testing. The guidance documents that explain how to do this were written for institutions where law enforcement response is measured in minutes, where mutual aid is a phone call away, and where the campus geography does not create evacuation constraints that make standard emergency protocols dangerous.

Running campus safety administration on an island campus is a different operational environment than those guidance documents describe. The Clery Act's geographic jurisdiction requirements — defining the campus, adjacent public areas, and non-campus locations that must be included in crime statistics — become complex on multi-island campuses, on campuses adjacent to Native Hawaiian cultural lands, and on campuses where the nearest police substation is a ferry ride away.

The gaps that island campus safety directors navigate

Emergency notification timing. The Clery Act requires timely notification of ongoing threats. On a campus with a 30-to-45-minute law enforcement response time, the threat is "ongoing" for a period that standard notification protocols were not designed for. The question of what information to communicate, how frequently to update it, and what guidance to give to campus community members during an extended response window is not addressed in federal guidance — because federal guidance was written for institutions where the response window is seven minutes.

Annual Security Report geographic jurisdiction. On a University of Hawaii campus with locations on multiple islands, defining the geographic scope of the Annual Security Report's crime statistics requires legal analysis that the Clery Act's guidance documents do not provide. On campuses adjacent to Hawaiian homelands or Native Hawaiian cultural properties, the "adjacent public area" definition involves questions about the relationship between state law, federal law, and Hawaiian land law that are specific to Hawaii and absent from any federal compliance guidance.

Behavioral threat assessment team composition. Campus threat assessment teams on island campuses face the same sole-provider workforce constraint that affects all small island institutions. When the only licensed mental health professional available for threat assessment consultation also has treatment relationships with students who may be subjects of concern, the conflict-of-interest management that standard BTAM guidance recommends is structurally complex in ways that continental guidance does not address.

ISPI's Campus Safety Framework for Geographically Isolated Institutions addresses all three gaps with practitioner-developed protocols. The full framework is available as a free download. Educational institutions commissioning island-calibrated campus safety assessments can contact ISPI at ISPIGlobal@proton.me.

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