stations throughout the United States are concerned about compliance
with FCC Emergency Alert System operational rules; EAS has become
perhaps the number one hot-button issue during commission
This is where the
duty officers hold forth 24/7 at the Washington State Emergency
Operations Center near Tacoma, Wash. Credit: Photos by Chris Moores
Of even more
importance, engineers are worried about how well EAS will serve their
audiences when real emergencies occur.
conducted an email interview with Clay Freinwald, an engineer closely
connected to EAS issues, to shed more light on practical questions
still being asked about emergency alerting implementation, even now,
long after the 2012 deadline for broadcasters to have Common Alerting
Protocol-compliant encoders/decoders operational.
Freinwald, owner of a technical service firm that bears his name, has
chaired the Washington State Emergency Communications Committee since
1997. He received the Radio World Excellence in Engineering Award in
do the FCC rules now require of stations regarding basic EAS
equipment that needs to be installed at all AM, FM, TV and cable TV
The FCC rules were changed a while back to include the requirement
that stations are all connected to and polling the FEMA Integrated
Public Alert and Warning System, in addition to their legacy
over-the-air monitoring assignments. The requirements are the same
for all the new LPFMs and LPTVs.
are the required station monitoring assignments established? Please
differentiate between Local Primary One (LP1) and Local Primary (LP2)
stations as well as National Weather Service, IPAWS and MyState
FCC, in its Part 11 rules, charges each state EAS committee —
meaning the SECC — to develop monitoring assignments. These are, as
they have been for years, legacy/analog sources and do not include
the FEMA/IPAWS Common Alerting Protocol server or any other system
that may be used by a state (MyStateUSA, EMNet, GSS, etc.)
the FEMA/IPAWS system is a blanket FCC requirement, states do not
address this issue or include it in their monitoring assignments.
It should be noted
that the FCC oversees monitoring assignments to ensure that the
sources of Emergency Action Notifications (Primary Entry Point
facilities, affiliated NPR and Premiere Network affiliates) propagate
to all radio, TV and cable systems.
An LP is a Local
Primary facility — not necessarily a broadcast station — whose
job it to monitor two redundant sources of national level EAS
messages — Emergency Action Notifications or National Periodic
Tests — and relay them to facilities within their coverage area.
There is no requirement that this architecture be followed; for
example, every station and applicable cable system could monitor both
sources and thereby eliminate the need for an LP.
NWS/NOAA Weather Radio is highly desirable due to the fact that the
majority of public warning messages are weather related; however,
there is no FCC requirement that this be done. There is, in my mind,
a huge moral obligation to do so.
RW: For a
long time, broadcasters’ participation in EAS has been described in
FCC rules as “voluntary” for many functions. But stations cannot
merely choose to completely “opt out.” What are the minimum
Only part of EAS is voluntary. The participation by all
stations and systems is required for the national level
portion of EAS, such as presidential messages, EANs and, of course,
testing of various portions of the system as described in Part 11 of
the FCC’s rules.
The carriage of
public warning messages from other sources, National Weather Service,
state and local governments, etc. is voluntary.
In the past,
stations could “opt out,” meaning should they receive an EAN,
they could turn off their station or cable system rather than
broadcast the message. The FCC eliminated this option. Today’s
rules require that everyone broadcast all national level EAS
messages, which are likely to be messages from the president.
Stations can opt out
of carrying messages from the National Weather Service, for example.
They do not have to carry tornado warnings or civil emergency
However, there is
certainly a moral obligation to do so. What would happen if a
broadcaster refused to carry a tornado warning and lives were lost as
a result? I suspect that the outcome of their “opting out” would,
potentially, create some serious issues.
EAS participants purchased new-generation encoding and decoding
equipment when CAP and IP connectivity were implemented. But some are
still using old legacy units for certain functions. How?
You can use what is commonly called a CAP converter. This is a unit
that is connected to the Internet for receiving messages from CAP
servers (national and otherwise) and relaying the messages to an
older model EAS unit. I don’t recommend this, as the newer EAS
units contain a number of great features that a station might well
find very useful.
exactly are the RWT and RMT record-keeping requirements? Can stations
dispense with paper logs and rely on digital files and information
contained inside the new-generation EAS encoders and/or stored on a
LAN to demonstrate compliance?
Recordkeeping of EAS activity is certainly a good idea. Sure, you can
keep these logs electronically; however, just like other items that a
station keeps track of, stations need to be asking the question:
“What is [our] procedure when an FCC inspector walks through the
Just for discussion,
let’s assume that this takes place when all of the department heads
are on a retreat and only the receptionist is in the building. Will
that individual be able to demonstrate EAS compliance and show the
inspector the logged information? And will they be able to perform
when the inspector asks this person to send a Required Weekly Test?
Automatic or computer logging does not relieve the station of EAS
MyState and IPAWS servers are relatively new players in the EAS
structure. Explain their roles.
MyState provides many services to state and local governments,
including the distribution of CAP-based public warning messages —
from the various message sources to the multiple systems that receive
them to forward them to the public. Several states use MyState as
their primary means of EAS message distribution, such as Washington,
Wisconsin, Nevada and Idaho, for example. MyState is just one of
several commercial enterprises that perform this task.
Washington State was
one of the first to employ its own CAP server (provided by MyState)
as a means of connecting the State Emergency Operations Centeras
well as counties and cities within the state to broadcasters and
other systems that reach the public. They were about four years ahead
of the national FEMA/IPAWS system.
The FEMA/IPAWS CAP
system connects the federal government to broadcast and cable systems
in a similar manner and can be used by state and local governments
completing agreements to do so and some are doing this, opting to not
have their own state system. The NWS will be using this system in the
Freinwald with the
EAS encoding/decoding equipment at the Washington State Emergency
Operations Center. From this location, the WS EOC launches
legacy/analog EAS messages via CAP for the state. The panel he’s
pointing to enables personnel to target a message to a portion of the
state. Credit: Photo by Chris Moores
RW: Do we
have to log these new sources as extra monitored assignments when
they conduct tests?
The FCC wants to make sure that all stations are connected and
receiving messages; logging is a means of assuring the regulators
that the system is complete. At this point there is no formal logging
requirement; however this could change.
EAS now relying more on Internet connectivity, what, in general, is
in place or being used by FEMA and at the state levels for backup
systems in the event a serious and widespread emergency occurs that
takes down large portions of Internet and cell services?
This one of the reasons why the legacy EAS systems are remaining in
place. For instance, EANs will not be distributed via the CAP
systems, but rather continue to use the legacy/analog EAS circuits
that have recently been augmented with the addition of Clear
Channel’s Premiere Networks. At most state and local levels, these
systems remain connected and tested regularly. These new
Internet-based systems should not be thought of as replacements of
legacy EAS systems but rather as augmentations.
Engineers are spending a lot of time tracking more tests to make sure
the required assigned monitored stations’ required weekly and
monthly tests were, in fact, received, relayed (when required) and
logged. What is expected of stations regarding compliance for tests
that were inadvertently missed or not executed properly by the
originating station or entity?
regarding what to do when a station misses a test have been in place
for many years. The station missing a Required Weekly Test or
Required Monthly Test is obligated to find out why the test was
missed and log the reason for the failure in their logs.
November 2011, the FCC and FEMA conducted the first nationwide EAS
test and learned a lot from that event. When will a follow-up test be
conducted and how might it differ?
great deal was learned from the last EAS national test and the FCC
released a great number of details about it late last year. One of
the CSRIC Committees is working on this facet of EAS. I can’t state
for sure when the next national test will take place; however, we can
be assured that the system will be tested again in the future.
Alerts have proven to be quite effective at locating and protecting
children from harm’s way. Are they required to be relayed when
transmitted over EAS systems?
No. Just like severe weather warnings or civil emergency warnings,
relaying them is 100 percent voluntary. As I have stated, I think
it’s repugnant that a broadcaster would chose to not wish to be a
part of airing a message that could indeed save lives.
the local announcers choose to read the alert information themselves
as a local area news bulletin item?
general terms and based on your experience, what aspects of EAS do
you feel need the most improvement for the system to better fulfill
its mission of protecting the public when a local, wide area or
national real emergency strikes?
The value of EAS could be considerably enhanced if it were more
utilized for the benefit of our citizens.
We have somewhat of
a Catch-22 here. First, broadcasters are reluctant to run many EAS
messages because they are of poor quality or could be viewed by
listeners as tuneouts, etc. Second, emergency managers and other
sources of these potentially life-saving messages either don’t
understand how EAS works or don’t wish to use if for fear that
broadcasters will not air the message.
This problem can
only be solved by working together. This is one of the major reasons
for the existence of the various state and local EAS committees. I
encourage every broadcaster with an interest in serving their fellow
citizens to get involved to — cooperatively — improve EAS.
Got a question
about EAS compliance? Send it to us and we’ll pass it along with
Clay Freinwald or the appropriate official. If we receive enough,
we’ll also publish them as a follow-up article.