Newly proposed rules from the FCC to improve the clarity and accessibility of the Emergency Alert System for the hearing impaired have raised questions from NAB about the vagueness of the proposal.
The proposed changes mostly deal with visual EAS messages for video services and addresses requiring “triggered” Common Alerting Protocol (CAP) polling, but NAB says it wants to make sure the FCC is clear when it comes to who will be affected by the changes.
“NAB has no significant objections to the proposals intended to improve the clarity and accessibility of nationwide EAS tests,” it began. But it says stations would need sufficient lead time to implement the changes, and it asked for clarity on how video-oriented changes would affect radio stations.
The move to amend Part 11 of the commission’s rules regarding EAS includes proposals for modifying text associated with national EAS tests, including pre-stored templates for NPT messages. NAB says using a predetermined script will provide a clearer description of the test than a strict translation of header code elements.
“This approach will also allow for a uniform visual message across different EAS devices and facilitate the ability of the national test message originator to ensure the audio component of the message matches the visual component,” NAB wrote in comments to the FCC.
NAB also in general supports increasing the use of CAP for video services, such as television stations, but suggests EAS participants will require sufficient lead time to implement an expanded use of CAP, which will depend on the availability of software upgrades to allow broadcasters to automatically poll the Integrated Public Alert and Warning System (IPAWS) for a CAP version of legacy alerts.
CAP-based alerts are transmitted over Internet Protocol (IP) links and can convey more information than legacy alerts, such as picture and URL links.
In addition, NAB asks the FCC to clarify that the new obligations for broadcasters to automatically seek and fetch CAP messages will apply only to video service EAS participants in order to alleviate confusion over the proposal. “There is no reason to burden audio service EAS participants with a new requirement, although some audio services may follow suit voluntarily for the sake of message consistency,” the group wrote.
The nonprofit trade association seeks confirmation from the FCC that a mandate for video services to check for and process CAP alerts can be effectuated through a software upgrade that is “simple and seamless” in all devices and at no cost to EAS participants. It also asks the commission not to adopt a date when all EAS participants must implement the change.
“The more efficient approach is for the FCC to establish a long enough runway to allow EAS participants to implement the change through a regularly scheduled software upgrade from the device manufacturer,” NAB commented.
NAB in its comments urges the commission to confirm and clarify that none of the latest EAS proposals will lead to reduced government commitment to legacy-based EAS alerting.
“Legacy EAS is more robust and survivable in the event of a significant national emergency,” NAB continued, “because, unlike CAP alerting, legacy EAS is not dependent of Internet access or affected by the loss or congestion of cellular and IP services during a storm.”
Lastly, the NAB seems to take a more forthright approach in addressing the vagueness of the FCC proposals and presumes the proposed obligation to poll for CAP version of legacy alerts is not intended to apply to audio service EAS participants, including radio stations: “There seems to be no reason to force radio stations to upgrade equipment or otherwise change their current practices, given the FCC’s purpose.”
The NAB continued: “Nonetheless, if the FCC can justify why the forced CAP polling mandate should also cover radio stations, NAB urges the FCC to extend radio broadcasters a lengthier period for implementation, such as two years from the effective date of a final order in this proceeding.”
The NAB notes that this will allow radio broadcasters sufficient time to consider methods for compliance suitable to their specific EAS equipment and processes.
Comments to FCC Docket 15-94 can be read here. Reply comments are due March 28.
The FCC also issued a companion Notice of Inquiry (NOI) that asked more forward-looking questions on how to improve the overall functionality of EAS. Comments on the NOI are due April 11 and replies by May 10.