Digital Alert Systems has submitted detailed comments in response to the NAB’s petition to fast track software-based Emergency Alert System solutions.
The manufacturer of EAS and CAP (Common Alert Protocol) products urged the FCC to reject or delay action on the NAB petition.
While DAS supports the broader goal of modernizing public alerting infrastructure, it says the NAB proposal overlooks key issues. In its 46-page filing, it stated that the petition fails to account for “a substantial array of unresolved regulatory, procedural, cybersecurity, operational and intellectual property questions.”
Without safeguards — particularly around compliance and cybersecurity — a shift to software-only systems could undermine “the very goals” of modernization, the company said.
Regulatory concerns
The FCC’s Part 11 rules govern EAS specifications, which requires hardware to undergo defined testing and certification processes. The NAB petition, DAS said, proposes removing that hardware certification requirement but fails to offer a clear alternative for certifying software-based systems.
“The challenge for the FCC would be to maintain an accurate and real-time inventory of which versions of EAS software are deployed and whether those versions comply with certification standards, a task that would become extremely difficult,” DAS wrote.
The company urged the commission to clarify whether software updates would require re-certification, how configuration changes would be documented and enforced and how consistent compliance could be ensured across computing environments.
DAS also expressed concern that creating separate regulatory paths for hardware and software would fragment the EAS market and potentially favor certain vendors unfairly.
Cybersecurity red flags
The company said that cybersecurity is a major unresolved issue. “There is currently no robust FCC cybersecurity standard tailored to EAS software platforms,” DAS wrote.
(Read Digital Alert Systems’ comments filed to the FCC on the NAB EAS petition.)
Software-only systems, it noted, are inherently more vulnerable to cyber threats like denial-of-service attacks, spoofing and disinformation. Many such systems would also rely on third-party hardware — platforms outside the FCC’s current oversight — making security and accountability even more complex.
DAS called for the development of cybersecurity-specific certification protocols, including threat monitoring and real-time risk assessments, which are functions that it said “traditionally fall outside” the FCC’s core expertise.
It echoed previous concerns from NAB that smaller broadcasters in particular lack the cybersecurity resources to take on these new responsibilities.
DAS also reminded the commission that EAS is part of the Department of Homeland Security’s list of critical infrastructure sectors. Moving to a software-only model without clear cybersecurity guardrails, it warned, could expose vital systems to unacceptable risks.
The petition, it said, does not address compliance with federal cybersecurity standards such as those from NIST, CISA or directives concerning supply chain security.
Operational and financial burden
The NAB petition, DAS said, provided no evidence that software-based EAS would improve reliability, accessibility or alert delivery.
[Related: “Letter: The FCC Should Allow Software EAS Systems”]
DAS warned that broadcasters would have to assume many responsibilities currently handled by hardware vendors, including patching, update management and version tracking.
“While large EAS participants may have the internal resources to securely deploy and manage software-based systems, thousands of small and medium-sized entities do not,” the company said.
Although software solutions may appear less expensive upfront, DAS argued they come with higher long-term costs in IT support, compliance and maintenance — especially burdensome for small operators.
Market disruption and hardware devaluation
DAS cautioned that shifting regulatory preference toward software-based systems could slow investment in new hardware development and destabilize the existing equipment supply chain.
“The shift away from traditional, certified physical systems in favor of less-regulated software alternatives may disrupt established market dynamics, potentially leading to long-term negative effects on industry stability, innovation and overall system reliability,” the company wrote.
It also warned that the petition could devalue existing platforms, including DAS’s DASDEC line.
Final recommendation
“We believe it would be irresponsible to rush into a regulatory environment that lacks clear rules, exposes EAS participants to increased cyber risks and fails to address the operational burden on EAS participant,” it wrote.
It said the FCC should take a cautious, deliberative approach on the matter to align with long-term resilience and reliability of the nation’s alerting system.
