In January, the FCC released
what appears to be the final Report and Order on the Emergency Alert System.
The Report and Order does not contain any further requests for comments,
suggesting that we have reached the final regulatory step in the years-long
undertaking to revise and create a modern EAS. I don’t have nearly the room
here to give a comprehensive analysis of all the changes the new rules
encompass, but I’ll try to go over some of the highlights.
For those who have been keeping close
track, there are a few eye-openers.
For me, the elimination of the “Governor Must-Carry” messages was
notable. The proposed rule would have bolstered the strength of state emergency
networks by forcing stations to carry alerts issued by an appropriate
The only problem was a constitutional one: There was no federal agency
(certainly not the FCC) with the authority to require states to provide such
alerting. As you can imagine, this is a touchy subject in some parts of the
United States, where “states’ rights” is a rallying political cry. The FCC
seems to have decided that the circle actually was a square all along; states
have the right to use the Integrated Public Alert and Warning System (IPAWS) to
distribute alerts. Since the FCC is allowed to require stations to carry
alerts, the problem would seem to be solved. States can “opt in” as they choose
with local alerting.
If you sport a “Non-participating National” designation, it
looks like your time is up — the FCC eliminated that little-used station
designation. The previous rules allowed NN stations to leave the air during an
actual Emergency Action Notification.
The concept used to be that all participating
stations would interrupt their local programming and connect to their local PEP
so that live and direct communications from Washington could be broadcast to
the country in a largely synchronous relay. That seems quaint by today’s
standards (though it brings to mind the drama of worldwide live communication as
portrayed in the fine movie “The King’s Speech” last year). In these more
practical times, an emergency text could be deployed literally in seconds
without having to create an actual live connection for the chief executive to
In tandem with eliminating the NN status, the FCC eliminated the
Emergency Action Termination. This allows EAS devices to receive national
emergency messaging in the same format of tests and AMBER alerts. Once the
message has been received and forwarded, stations can automatically return to
their regular programming once an End of Message (EOM) code has been issued.
One final important deletion: There
will be no “text to speech” conversion allowed in CAP. Personally I liked this
idea. If a message has to come a long ways, it is cleaner to turn it back from
text to speech locally. But we’ve all heard what happens when it fails, as well
as the inherent problems TTS has with place names. Save this one until next
round and hope that technology improves.
A LONG ROAD TO THE FIRST STEP
round of modernization of EAS has taken years. Overall, I have to applaud the
efforts of everyone involved. As far as I can tell, all parties have been
guided by the best of intentions. Let’s give kudos to the manufacturing community
that worked closely with broadcasters to develop the ECIG, the EAS-CAP Industry
Group and its best practices document. Broadcasters’ guiding agency, the FCC,
had to coordinate with other federal agencies, each with its own agenda and
timetable. Many other agencies and administrators had to finalize their
decisions before the FCC could even get to the point of proposing new rules. In
the end, a truly radical change of the EAS system was not yet possible, even
though I would wish that we could have done more.
To my mind, the crucial step has been
made to create what is essentially a parallel distribution system for emergency
alerting. The Common Alert Protocol, CAP, offers the essential ability to
distribute messages via the public or private Internet. But enough doubts
remained about the reliability of the public Internet that the main components
of the daisy chain method of national emergency messaging were retained.
We will still have Primary Entry Points (in fact more of them) and state
plans that move alerts from one station to another, even though the technology
to target local alerts directly has been around for quite some time. Many
forward-looking states already use these more modern techniques, but the
federal government could not at the last analysis force all states to modernize
The positive side is that with CAP in
place late this spring, it will be possible to begin to answer reliability
questions that right now are somewhat speculative. With the National EAN test
under our belts, it will now be possible to compare the reliability of CAP
distribution to legacy methods using a closed-circuit test. Does anyone really
think the results will be worse than what happened in November? And if it works
the way it should, the road toward eliminating bottlenecked state plans has a
clear path — use IPAWS.
To my mind, the goal is to get to a
more reliable, yet mostly silent EAS. If IP distribution works and can be
successfully demonstrated then the concept of moving tests off the air and into
computers has been shown to be viable. CAP should help to get us there.
IS ANYONE STILL LISTENING?
interesting point was raised recently by Andrew Stringer on the AWARE website,
which focuses on public safety. See www.awareforum.org/2012/01/recap-of-2012-ces-is-broadcast-dead/
for the full entry.
Stringer raised the question of whether
all this work on EAS was only a partial solution to a problem that was
While the design and implementation of the new EAS has been plodding its
way to completion, the media landscape has been changing rapidly. It’s hard to
recall, but when the process to modernize EAS was begun (the First Report and
Order dates to November 2005), there was no such thing as a smartphone, and
wireless networks in the United States were just deploying 3G systems so that
consumers could receive wireless data at rates better than a dial-up modem.
Today, 4G rapidly is gaining ground and delivering data rates to mobile
devices that outstrip what was known as “high-speed Internet” just a few years
ago. Consumers are presented with any number of available gadgets that provide
entertainment and information anywhere and everywhere they go, not just at home
or in the automobile.
Naturally, this raises questions of
relevance:Have we modernized EAS
at great effort and expense, only to find that consumers can no longer be
reached this way?
Studies have shown that a large portion
of audio streaming is of radio station signals themselves. Did we forget to
include rules that require insertion to internet streams (a relatively minor
change)? What about Internet streams not originating from radio
broadcasters?The FCC certainly
has no authority over them (nor does anyone at this point in time, for that
Stringer’s point was that emergency management leaders have to start
thinking about these new entertainment mediums and how to make them part of
One idea that was under consideration just a couple of years ago was to
try to have all cellphones and portable devices contain an FM tuner. It is a
fairly simple step from there to have it activate upon receiving an EAS alert.
Clearly this is a powerful solution to alerting on music/program storage
devices like iPods. However, the idea caused much upset at the Consumer
Wireless companies have proposed and are just in the early
stages of testing a geographically sensitive “robo texting” as part of the
Commercial Mobile Alert System (CMAS), their version of EAS. We’ll see if it
can actually handle the potential traffic of an EAN and its associated 100
million or so text messages simultaneously reaching cellphones. At least it’s
comforting to know that other communications entities have had to travel a
similar path and regulatory burden.
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