Engineers at stations throughout the United States are concerned about compliance with FCC Emergency Alert System operational rules; EAS has become perhaps the number one hot-button issue during commission inspections.
Of even more importance, engineers are worried about how well EAS will serve their audiences when real emergencies occur.
Radio World conducted an email interview with Clay Freinwald, an engineer closely connected to EAS issues, to shed more light on practical questions still being asked about emergency alerting implementation, even now, long after the 2012 deadline for broadcasters to have Common Alerting Protocol-compliant encoders/decoders operational.
The Seattle-based Freinwald, owner of a technical service firm that bears his name, has chaired the Washington State Emergency Communications Committee since 1997. He received the Radio World Excellence in Engineering Award in 2007.
RW: What do the FCC rules now require of stations regarding basic EAS equipment that needs to be installed at all AM, FM, TV and cable TV facilities?
Freinwald: The FCC rules were changed a while back to include the requirement that stations are all connected to and polling the FEMA Integrated Public Alert and Warning System, in addition to their legacy over-the-air monitoring assignments. The requirements are the same for all the new LPFMs and LPTVs.
RW: How are the required station monitoring assignments established? Please differentiate between Local Primary One (LP1) and Local Primary (LP2) stations as well as National Weather Service, IPAWS and MyState server monitoring.
Freinwald: The FCC, in its Part 11 rules, charges each state EAS committee — meaning the SECC — to develop monitoring assignments. These are, as they have been for years, legacy/analog sources and do not include the FEMA/IPAWS Common Alerting Protocol server or any other system that may be used by a state (MyStateUSA, EMNet, GSS, etc.)
Whereas monitoring the FEMA/IPAWS system is a blanket FCC requirement, states do not address this issue or include it in their monitoring assignments.
It should be noted that the FCC oversees monitoring assignments to ensure that the sources of Emergency Action Notifications (Primary Entry Point facilities, affiliated NPR and Premiere Network affiliates) propagate to all radio, TV and cable systems.
An LP is a Local Primary facility — not necessarily a broadcast station — whose job it to monitor two redundant sources of national level EAS messages — Emergency Action Notifications or National Periodic Tests — and relay them to facilities within their coverage area. There is no requirement that this architecture be followed; for example, every station and applicable cable system could monitor both sources and thereby eliminate the need for an LP.
Monitoring the NWS/NOAA Weather Radio is highly desirable due to the fact that the majority of public warning messages are weather related; however, there is no FCC requirement that this be done. There is, in my mind, a huge moral obligation to do so.
RW: For a long time, broadcasters’ participation in EAS has been described in FCC rules as “voluntary” for many functions. But stations cannot merely choose to completely “opt out.” What are the minimum requirements?
Freinwald: Only part of EAS is voluntary. The participation by all stations and systems is required for the national level portion of EAS, such as presidential messages, EANs and, of course, testing of various portions of the system as described in Part 11 of the FCC’s rules.
The carriage of public warning messages from other sources, National Weather Service, state and local governments, etc. is voluntary.
In the past, stations could “opt out,” meaning should they receive an EAN, they could turn off their station or cable system rather than broadcast the message. The FCC eliminated this option. Today’s rules require that everyone broadcast all national level EAS messages, which are likely to be messages from the president.
Stations can opt out of carrying messages from the National Weather Service, for example. They do not have to carry tornado warnings or civil emergency messages.
However, there is certainly a moral obligation to do so. What would happen if a broadcaster refused to carry a tornado warning and lives were lost as a result? I suspect that the outcome of their “opting out” would, potentially, create some serious issues.
RW: Many EAS participants purchased new-generation encoding and decoding equipment when CAP and IP connectivity were implemented. But some are still using old legacy units for certain functions. How?
Freinwald: You can use what is commonly called a CAP converter. This is a unit that is connected to the Internet for receiving messages from CAP servers (national and otherwise) and relaying the messages to an older model EAS unit. I don’t recommend this, as the newer EAS units contain a number of great features that a station might well find very useful.
RW: What exactly are the RWT and RMT record-keeping requirements? Can stations dispense with paper logs and rely on digital files and information contained inside the new-generation EAS encoders and/or stored on a LAN to demonstrate compliance?
Freinwald: Recordkeeping of EAS activity is certainly a good idea. Sure, you can keep these logs electronically; however, just like other items that a station keeps track of, stations need to be asking the question: “What is [our] procedure when an FCC inspector walks through the door?”
Just for discussion, let’s assume that this takes place when all of the department heads are on a retreat and only the receptionist is in the building. Will that individual be able to demonstrate EAS compliance and show the inspector the logged information? And will they be able to perform when the inspector asks this person to send a Required Weekly Test? Automatic or computer logging does not relieve the station of EAS responsibilities.
RW: MyState and IPAWS servers are relatively new players in the EAS structure. Explain their roles.
Freinwald: MyState provides many services to state and local governments, including the distribution of CAP-based public warning messages — from the various message sources to the multiple systems that receive them to forward them to the public. Several states use MyState as their primary means of EAS message distribution, such as Washington, Wisconsin, Nevada and Idaho, for example. MyState is just one of several commercial enterprises that perform this task.
Washington State was one of the first to employ its own CAP server (provided by MyState) as a means of connecting the State Emergency Operations Centeras well as counties and cities within the state to broadcasters and other systems that reach the public. They were about four years ahead of the national FEMA/IPAWS system.
The FEMA/IPAWS CAP system connects the federal government to broadcast and cable systems in a similar manner and can be used by state and local governments completing agreements to do so and some are doing this, opting to not have their own state system. The NWS will be using this system in the future.
RW: Do we have to log these new sources as extra monitored assignments when they conduct tests?
Freinwald: The FCC wants to make sure that all stations are connected and receiving messages; logging is a means of assuring the regulators that the system is complete. At this point there is no formal logging requirement; however this could change.
RW: With EAS now relying more on Internet connectivity, what, in general, is in place or being used by FEMA and at the state levels for backup systems in the event a serious and widespread emergency occurs that takes down large portions of Internet and cell services?
Freinwald: This one of the reasons why the legacy EAS systems are remaining in place. For instance, EANs will not be distributed via the CAP systems, but rather continue to use the legacy/analog EAS circuits that have recently been augmented with the addition of Clear Channel’s Premiere Networks. At most state and local levels, these systems remain connected and tested regularly. These new Internet-based systems should not be thought of as replacements of legacy EAS systems but rather as augmentations.
RW: Engineers are spending a lot of time tracking more tests to make sure the required assigned monitored stations’ required weekly and monthly tests were, in fact, received, relayed (when required) and logged. What is expected of stations regarding compliance for tests that were inadvertently missed or not executed properly by the originating station or entity?
Freinwald: Rules regarding what to do when a station misses a test have been in place for many years. The station missing a Required Weekly Test or Required Monthly Test is obligated to find out why the test was missed and log the reason for the failure in their logs.
RW: In November 2011, the FCC and FEMA conducted the first nationwide EAS test and learned a lot from that event. When will a follow-up test be conducted and how might it differ?
Freinwald: A great deal was learned from the last EAS national test and the FCC released a great number of details about it late last year. One of the CSRIC Committees is working on this facet of EAS. I can’t state for sure when the next national test will take place; however, we can be assured that the system will be tested again in the future.
RW: Amber Alerts have proven to be quite effective at locating and protecting children from harm’s way. Are they required to be relayed when transmitted over EAS systems?
Freinwald: No. Just like severe weather warnings or civil emergency warnings, relaying them is 100 percent voluntary. As I have stated, I think it’s repugnant that a broadcaster would chose to not wish to be a part of airing a message that could indeed save lives.
RW: Can the local announcers choose to read the alert information themselves as a local area news bulletin item?
RW: In general terms and based on your experience, what aspects of EAS do you feel need the most improvement for the system to better fulfill its mission of protecting the public when a local, wide area or national real emergency strikes?
Freinwald: The value of EAS could be considerably enhanced if it were more utilized for the benefit of our citizens.
We have somewhat of a Catch-22 here. First, broadcasters are reluctant to run many EAS messages because they are of poor quality or could be viewed by listeners as tuneouts, etc. Second, emergency managers and other sources of these potentially life-saving messages either don’t understand how EAS works or don’t wish to use if for fear that broadcasters will not air the message.
This problem can only be solved by working together. This is one of the major reasons for the existence of the various state and local EAS committees. I encourage every broadcaster with an interest in serving their fellow citizens to get involved to — cooperatively — improve EAS.
Got a question about EAS compliance? Send it to us and we’ll pass it along with Clay Freinwald or the appropriate official. If we receive enough, we’ll also publish them as a follow-up article.
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