What “000000” Means to You
     

Viewers of Nickelodeon on Comcast Cable in Lancaster, Pa., saw this slide during the 2011 test, as captured on YouTube.
Some 2 1/2 years after the first national Emergency Alert System test, the FCC is ready to apply some of the lessons it learned.

“The actions we take today are the first in a series of steps to enhance the existing paradigm for the testing, exercise and use of the EAS in a way that maximizes its overall effectiveness as a public alert and warning system,” the commission wrote in a Notice of Proposed Rulemaking in late June.

The proposed rule changes, it continued, are needed to facilitate a second nationwide test. The Federal Emergency Management Agency wants to hold another one soon, ideally involving the entire Integrated Public Alert & Warning System, of which EAS is a part (as is the new Wireless Emergency Alert system that sends messages to cellphones).

An earlier FCC report described the national EAS distribution architecture as fundamentally sound but outlined problems uncovered by the test including poor audio quality, lack of Primary Entry Point stations, short test length and inconsistencies in EAS hardware programming. Some of these problems have been taken on by FEMA, not the FCC, to solve. But here’s what the commission wants to do soon:


Create a national location code for alerts issued by the president.
— EAS equipment uses geographic location codes; but the rules don’t contain a code for the entire United States. The commission had chosen not to adopt one, citing cost concerns for equipment users. For the test, the FCC and FEMA used the code for Washington, D.C. This led to problems with equipment rejecting the “out of area” alert and terminating the test early.

The FCC plans to require EAS participants, including radio stations, to be able to receive and process a national location code. The code would be six zeroes, 000000. This would make EAS consistent with Common Alerting Protocol standards and let FEMA use other codes for geo-targeted messages, should the president wish to address just a particular part of the country.

This change, however, also could make some “legacy” EAS equipment obsolete, or involve labor to update software in existing EAS equipment.


Facilitate use of a national EAS test code for nationwide tests. —
FEMA initiated the 2011 test by delivering an Emergency Action Notification to Primary Entry Point stations. The EAN, as most readers know, is the “live” code that would be used by the president in a real emergency, but using it for a test involves risks, including possible confusion when viewers see video text crawls about a national emergency.

If they could use a National Periodic Test code instead, federal authorities would not have to conduct a public outreach campaign ahead of a national test. FEMA would like to use the NPT code next time it tests EAS.

The FCC agrees there should be a non-EAN option for EAS testing and that the NPT is the “obvious alternative,” so it plans to establish that option; but it isn’t sure how it should be deployed.

FEMA thinks this code should be handled in the same way and with the same immediacy as an EAN. But others say requiring such a level of consistency will end up costing EAS participants too much money and hassle. They told the FCC that it would be cheaper and easier to enable the NPT as it is currently programmed in most EAS gear, a less intrusive approach that would offer most of the benefits of an EAN test and help FEMA schedule another one sooner.

Yet that approach would not provide the fullest possible test; it would not test the reset functionality of EAS equipment by lasting longer than two minutes, nor would it override all other EAS alerts. Shouldn’t a national test approximate real emergency conditions as much as possible?

The FCC asked a half-dozen questions in its NPRM about NPT implementation alone, seeking comments from anyone with an interest in EAS.


Require broadcasters and other participants to file test result data electronically.
— The “vast majority” of the 16,000 participants who responded with data about the 2011 test did so online. So the commission plans to adapt the system it used then and require its future use. The filing system should be improved, though, so a station could preview data before submitting; and users should get a filing receipt, the lack of which caused hassles for some broadcasters.

The commission thinks its updated EAS Test Reporting System can help authorities see how an EAN or any other alert is propagated through the EAS architecture, and to help detect vulnerabilities. It would also be a relief to State Emergency Communication Committees, which are supposed to have supplied the FCC with data tables showing monitoring assignments and message paths but have not yet been able to do so. The FCC thinks data from its ETRS could be used to create those data tables and a planned FCC “Mapbook” that organizes stations and cable systems by state, EAS Local Area and EAS designation.


Require participants to meet certain standards to ensure that alerts are accessible to everyone, including people with disabilities. —
The commission wants to set minimum standards for EAS visual crawls, “specifically with respect to crawl speed, completeness and placement.” Because these do not affect most RW readers, I won’t detail them here,

but you can read about them at the link I’ll give below. It also asked for comments about improving the accessibility of EAS audio by taking steps to ensure that audio and visual elements of an EAS alert convey the same or comparable info. Because audio and visual elements of an alert are generated from different sources, they can differ in language and detail, the FCC wrote. “We believe that for an EAS alert to be fully accessible, the audio and visual elements should convey the same message. What steps would need to be taken to achieve this goal?”


The FCC wants your comments on these changes and on how quickly they could be implemented; so file your comments at www.fcc.gov in EB Docket No. 04-296. (Remember to copy me at radioworld@nbmedia.com, too, so we can publish them in our letters section.)

Before doing so you might wish to read what the FCC plans in detail, so I’ve posted the text of the NPRM at http://tinyurl.com/orxjwft.

Note that the commission plans to consider other enhancements later, such as standardizing the waiver process for “live code” exercises, streamlining the state plan process and adding other elements of IPAWS to the testing process. It acknowledged that routine testing of the entire IPAWS is desirable, but for now it wants to focus on the four goals above.


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