One voice in the world of EAS and equipment manufacturing said some of the changes being proposed by the current EAS proceeding may be going too far.
James T. Gorman, founder of Gorman-Redlich Mfg. Co., which manufacturers emergency alert system equipment, said in a comment filing with the Federal Communications Commission that some of the proposals in the commission’s EAS Notice of Proposed Rulemaking “appear to go too far and may result in chaos for both station personnel and equipment manufacturers.”
Gorman noted one proposal in the EAS Notice of Proposed Rulemaking that suggests use of an type of authentication code within the EAS alert. Gorman said that any solution that involves adding a digital data burst at the beginning of the spoken message would be a huge amount of work to decode.
He specifically addressed the issue of malicious or accidental emergency action notification, saying that this is the kind of situation in which the FCC should consider a simple solution to this problem — as opposed to more complex alternative to avoid inadvertent or malicious alerts.
For example, it’s possible to avoid the inadvertent issue of an EAN by an inexperienced operator who is attempting to generate a test alert by simply removing the option of selecting the EAN event code from stations that are not designated as primary entry point, or PEP, stations.
Solutions like these would not require any changes to the EAS header code and would likely be inexpensive to implement, Gorman said.
Gorman pointed out that false emergency alerts can be avoided by checking the so-called Julian date of an incoming message and comparing that to the current Julian date. This is one solution to resolving the unintended issuance of an EAN, such as the one that occurred in October 2014 during the broadcast of the nationally syndicated program “The Bobby Bones Show,” in which a a false emergency alert was sent out.
He also said the estimated cost of implementing the changes are far higher than estimated. These estimated costs do not take into account the time and resources needed for manufacturers to make equipment changes and to field support calls from users as they work to meet the new requirements. “[These steps are] in addition to the time and resources required for station personnel to upgrade equipment, learn new procedures, ensure compliance with new rules, etc.,” Gorman said in his filing with the commission.
Gorman also addressed the issue of cost. He pointed to previously submitted comments in the proceeding that said a disproportionate financial burden from these new EAS requirements looks to fall on LPFM and LPTV facilities. “The equipment costs already represent a larger portion of low-power stations’ budgets, many of whom do not have a full-time engineer and rely on other station personnel or manufacturer support to perform engineering duties when budgets do not allow for a contract engineer,” Gorman said.
He also reiterated his opposition to some technical suggestions, such as making any changes in the middle of the FSK string to identify the year. “[Our firm] has done internal testing with additional data at the end of the EAS header data FSK, and it seems to have no effect on the operation of our unit in receiving or processing messages,” he said.
Gorman’s comments were submitted as part of the commission’s EAS NPRM. Reply comments are being accepted on Proceeding Number 15-94 through July 8.
