This fall saw a flurry of activity on the Common Alert Protocol front. Rumors had been flying since April that Federal Emergency Management Agency deliberations were nearly at an end. Sure enough, on Sept. 30, FEMA announced it was officially adopting the Common Alert Protocol Standard v1.2.
This decision started the “CAP timer” or “shot clock,” created by the FCC in a Report and Order released July 12, 2007. In that order, the FCC made it a requirement that all EAS participants be able to accept CAP-based alerts within 180 days of the adoption of CAP by FEMA. Thus, once FEMA acted, we all had until the end of March 2011 to purchase and install new equipment. Or so we were told at first.
Technically, some stations have already installed CAP-capable gear; for example, anyone who has purchased new equipment in the last couple of years most likely bought something with CAP capability. Many others have money set aside to purchase the equipment soon. After all, FEMA announced its intention to adopt CAP back in July 2008. It took a while for the final reviews to ensure them that CAP was the way to go for the new Integrated Public Alert and Warning System, which is supposed to operate across pretty much any media platform that you can think of, including cell phones.
The fact that we had all been told years ago that the Emergency Alert System was going to change and require new equipment didn’t stop an initial round of panicked comments, even defiance, from some broadcast quarters. The argument that someone was somehow unaware of this requirement and can’t afford to purchase new equipment doesn’t seem to hold much water given the number of years that this has been under discussion. However, there are some legitimate reasons why the 180-day timer was a bit too hasty.
ROUND TWO
Enter the NAB and an impressive range of other supporters with a petition to delay the CAP adoption by another six-month period. National Public Radio, Society of Broadcast Engineers, Association for Maximum Service Television, the Public Broadcasting Service and no fewer than 46 state broadcasting associations all signed on to this request.
It turns out that there is a certain amount of unfinished business that the FCC was unable to complete while waiting for FEMA to act.
First, it isn’t completely clear just how the new EAS system with CAP is supposed to work. While several manufacturers have built equipment that can decode CAP messages, it isn’t quite that simple — equipment will have to provide the necessary features and operations that allow consistent EAS operation. The EAS CAP Industry Group recommendations are an excellent starting point but these have yet to be formally accepted. The petitioners have also requested that the FCC certify compliance of new-generation EAS equipment to make sure that broadcasters are buying what will actually be needed.
Indeed, the Communications Security Reliability and Interoperability Council, whose mission is to provide recommendations to the FCC on security and reliability of public communications and public safety, agrees that the FCC should separately certify equipment. And in a report approved in October 2010, the CSRIC makes a number of additional recommendations to the FCC regarding CAP implementation.
Key among these recommendations are the following:
- – Clarification of governor’s “must carry” implementation
- – Requirement that EAS participants monitor multiple IP-based alert sources
- – Revision of EAS Equipment Requirement Tables
- – Requirement of Ethernet input to monitor for alerts
It was hard to see how manufacturers can produce compliant equipment and stations can purchase the correct complement of equipment until these recommendations are acted on. The CSRIC acknowledged this in its own recommendation to extend the compliance period for EAS participants.
WHAT ABOUT THE RULES?
Finally, as a legal matter, the FCC will need to make a number of changes to the rules regarding EAS.
While this is perfectly controllable by the FCC, the process will still require the issuance of a Notice of Proposed Rulemaking and the necessary comment periods before the new rules can be adopted. Even assuming a fairly rapid pace at the FCC, this final step probably wouldn’t be complete until nearly March 2011, or right about when the CAP timer was to run out. That didn’t give manufacturers and stations much time to comply, even if most stations were to go out and purchase a base system today and plan to modify it as necessary once the rules become clear.
The CSRIC report includes a thorough description of the rules changes to Part 11 of the Code of Federal Regulations that will be required in order to include CAP in the Emergency Alert System. There are too many changes for me to include them all here but it makes for interesting reading if you want to watch the cogs of government turning. The CSRIC report is publicly available at tinyurl.com/rwcap.
SECOND GUESSES
Just before our issue went to press, the FCC did indeed extend the deadline, to the end of September. That’s wise. Making broadcasters purchase equipment that will not necessarily satisfy the new legal requirements would not have been good or effective government. Public safety is an important mission for broadcasters; but if we want this upgrade to work, all pieces should be in place before we go spend time and money.
Meanwhile, we hope for more clarity on exactly what it means to be in compliance. So keep your ears to the ground, download a copy of the ECIG to read and start to think about how you plan CAP modifications. As much as the argument today is about new equipment, in the end it is the engineer’s business to spend the time and figure out exactly how to make the whole thing work at the station level. And there is little doubt that the requirement will be coming soon.
