Abbott: FCC Proposal Has Hidden Costs

She says states all adopted AMBER without need for a new event code
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One in a series about a proposed Blue Alert EAS code.

Adrienne Abbott is Nevada’s state EAS chair but filed comments to the FCC her own behalf in this instance.

Abbott emphasized that she supports the idea of Blue Alert programs, but like several others in the broadcast community she identifies concerns about how the FCC is approaching this proposal.

She said law enforcement officials already have the ability to use the Emergency Alert System to issue warnings about suspects who pose an imminent and credible threat through the LEW or Law Enforcement Warning Event Code listed in Part 11 of the EAS rules.

“The FCC does not provide specific definitions for the non-Presidential Event Codes,” she reminded the commission. “Instead, individual states have the ability to define non-weather Event Codes in their EAS Plans. The Office of Community-oriented Policing Service of the U.S. Department of Justice should encourage local law enforcement agencies to work with their State Emergency Communications Committees to produce Blue Alert Plans in each state, similar to what the DoJ did for AMBER Alerts.”

She reminded the commission that the Child Abduction Emergency (CAE) Event Code was in Part 11 before various abducted child alert programs coalesced around the AMBER Alert. “We had the ‘Krystal Alert’ here in Nevada. Other states had similar child abduction programs such as the ‘Malcolm Alert’ or ‘Rachel Alert.’ The CAE Event Code was designed to cover these programs before every state adopted the term ‘AMBER Alert’ for their abducted, endangered children programs,” Abbott wrote.

“It was the unifying efforts of the DoJ and the National Center for Missing and Exploited Children which resulted in the success of all states adopting the term ‘AMBER Alert’ without the need for a new Event Code.”

She said that by using an existing Event Code instead of a new one, stations and other EAS participants both large and small would not have to purchase an upgrade. “EAS equipment providers have offered several recent upgrades for new EAS Event Codes at no cost to their customers but most have noted that they can’t afford to continue providing free upgrades.”

Also, if a dedicated Blue Alert Event Code is implemented, she estimates it would take two years for the full process, not the six months proposed for participants to install updated equipment. “There will be a need for new EAS Plans to be written to accommodate the use of the Blue Alert, law enforcement agencies to purchase and train on new IPAWS CAP technology so that they can issue Blue Alerts, existing [Collaborative Operating Groups] will need to be re-credentialed and updated to add the Blue Alert Event Code to their list of approved codes, and public awareness campaigns will have to be conducted to train broadcast audiences and cell phone users about the Blue Alert.”

Further, the addition of a Blue Alert will require re-writing EAS Plans. Many states, she said, only recently rewrote theirs and may not have funding or personnel for an update.

Abbott identified a hidden cost to implementing a Blue Alert Event Code. The FCC proposal, she said, doesn’t consider the expense to state and local government agencies to pay to update existing IPAWS CAP tools and add law enforcement agencies to those Collaborative Operating Groups, COGs, assuming the state already has access to IPAWS CAP.

“Not all states have access to IPAWS CAP, so separate provisions would have to be made for how agencies in those states would issue Blue Alerts. Then the law enforcement agencies would have to develop their own policies for issuing the Blue Alert and the staff would have to be trained in the use of the CAP tools to issue a Blue Alert activation on both the EAS and Wireless Emergency Alert platforms. The state and local COGS would also have to be re-credentialed for the new Event Code.” All of this would cost state and local agencies. Even if federal grant money is available, she said, the taxpayer ultimately bears that burden.

“Adopting a Blue Alert program using the current LEW Event Code lessens the cost,” she said. “State and local law enforcement agencies will still need to be added to existing COGs and trained on the existing CAP tools. There would be a cost to the state and local agencies for new EAS Plans, the updates to existing CAP tools, new credentials and training programs.

“There is no indication in the NPRM for who would be responsible for overseeing these activities.”

In a separate email to Radio World, Abbott expressed the opinion that using the existing LEW Event Code would allow for the implementation of the Blue Alert program sooner than if the FCC approves an entirely new Event Code.

“Like many of us in the broadcast industry, I have close ties to the law enforcement community,” she added. “I’ve lived through and reported on and engineered around events which should have had EAS activations to inform and protect the community. If nothing else, this discussion over the Blue Alert program will raise awareness of the availability of EAS for law enforcement-related public warnings.”

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