Broadcasters associations across America are in agreement over the benefits to software-based emergency alerting. But those benefits also shouldn’t jeopardize perfectly functioning hardware and risk, the associations believe, what makes the EAS system work in the first place.
Associations that represent radio and TV broadcasters from 49 U.S. states expressed those sentiments in a joint filing to the Federal Communications Commission put forth by an attorney on their behalf.
They support software-based EAS, but on a voluntary basis. The filing, submitted Sept. 29, pushed for flexibility, explaining that if a station’s hardware is working just fine, the station should be allowed to continue using it.
The state associations frame their viewpoint under the stance that a solution suitable for a large TV broadcast group might not be suitable for a single radio station operator.
(Read the joint broadcasters association comments.)
“The commission therefore should allow each EAS participant to choose the certified hardware- or software-based solution that best fits its operations,” they wrote.
The joint filing also concurred with prior comments from the National Association of Broadcasters that urged the commission to maintain the existing 60-day repair-or-replace period for software-based EAS, as well as to improve message authentication through a measured process.
The FCC’s Further Notice of Proposed Rulemaking proposes to allow broadcasters and other EAS participants to use software to replace EAS hardware if they wish. The deadline for reply comments on the FNPRM was Sept. 29.
The best fit
To be clear, the associations see the the benefits of software-based systems. Endorsing NAB, the associations cited better support for remote updates, integration with current broadcast systems and reduced dependence on “purpose-built” hardware.
But they emphasized those benefits should be realized without requiring stations to replace or discontinue use of a functioning hardware-based system.
Software-based EAS should also satisfy performance, security and reliability requirements before it is used or marketed, the associations wrote.
The commission should draw on manufacturer expertise in developing those requirements, they added, and permit routine maintenance, security patches and other updates without recertification.
To that end, the associations also echoed the sentiments of NAB that the FCC should apply the existing 60-day period for repairing or replacing defective EAS equipment to software-based EAS, rather than a 72-hour deadline.
That 72-hour window would discourage the use of such systems, the associations warned. The FCC should not assume that every software-related problem can be diagnosed and corrected within three days, they added.
Authentication
As we have covered in depth, the commission wants to require that broadcasters and other EAS participants reject CAP EAS messages that do not include a valid digital signature.
The FCC believes its proposal represents “a major step forward” in securing CAP EAS alerts and thinks the requirement would be “technically straightforward” because EAS equipment already must authenticate signed CAP EAS messages.
But the associations cautioned that any new digital-signature requirement should be through a process with clear standards and implementation time. This is particularly needed, they said, for those legacy messages transmitted with Specific Area Message Encoding.
As other parties have noted, the National Weather Service does not use digital signatures to authenticate EAS transmissions. Any implementation schedule, the associations urged, should account for NWS transmission practices and provide manufacturers time to develop and test solutions.
“The resulting mechanism should not delay or reject valid alerts or disrupt automated relay,” the associations wrote. “It also should not require broadcasters to replace functioning equipment.”
The commission should permit, but not require, EAS participants to use CAP circles and polygons when assessing the geographic relevance of state and local alerts, they continued.
Coordinates, the broadcast associations stated, can help stations connect an emergency to their signal coverage. They noted the broad reach of conventional EAS, which can reach population centers through a single transmission along with rural and outlying communities.
State members help develop and implement state EAS plans, so the associations pointed to Sage Alerting Systems’ concern that mandatory polygon-based filtering could disrupt established monitoring assignments by preventing an alert from reaching a downstream station.
“CAP geographic data should therefore remain an optional tool for informed local judgment,” the associations wrote.
Similarly, the associations preached caution about the adoption of new legacy EAS location codes where county and partial-county descriptions are inadequate. They noted NAB and Sage concerns on limitations of the location field, coordination with NWS and compatibility with installed equipment.
Finally, the associations believe that technical changes alone cannot ensure effective alerting. “New requirements involving authentication, identifiers, geographic information, location codes or presentation will require coordinated implementation throughout the alerting ecosystem,” they wrote.
They ask the commission to work with FEMA and IPAWS to provide guidance and training before compliance becomes mandatory. That guidance should explain participants’ responsibilities and the effects of the new requirements on CAP and legacy pathways, state EAS plans and monitoring assignments.
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