WASHINGTON — Comments to the FCC indicate that several equipment-related questions remained unsettled in August, as the commission considered changes to Part 11 rules governing EAS.
Those changes are planned to support the move toward emergency message delivery using a Common Alerting Protocol. CAP is a data interchange protocol developed by the emergency management community; it is used to distribute all-hazard safety notifications and emergency warning information. It allows a warning message to be disseminated simultaneously over many warning systems to many applications.
Proponents say it is an improvement over legacy EAS, allowing for better delivery, higher-fidelity audio, text-to-speech when audio is not available, matching audio and text, and other benefits.
Based on the filed comments, opponents generally are not against the implementation but object to its timing so close to the planned first national EAS test, and to the fact that many stations have been obliged to order new gear even though broadcast CAP-EAS system requirements have not yet been finalized.
Speaking to Radio World, one engineer for a large radio group recently described the CAP-EAS system as essentially still in “beta” mode.
The commission is reviewing public comments filed to Docket 04-296. Beyond the matter of extending the compliance deadline, covered in our Aug. 10 issue, broadcasters and equipment manufacturers express varied opinions about updates necessary to the rules to accommodate migration to a next-gen EAS.
Chief among the concerns is whether the FCC will accept the use of CAP-to-EAS converters and whether it will conduct its own equipment conformance testing for new gear rather than accept FEMA’s findings.
Some commenters called for the revocation of all exemptions from participating in EAS; all classes of stations then would need both EAS encoders and decoders. Others suggested retiring required weekly EAS tests.
Here are excerpts of filed comments.
Allow CAP Converters …
Several executives contributed to a filing by the National Association of Broadcasters. Executive Vice President of Legal & Regulatory Affairs Jane Mago headed the list and wrote:
NAB supports the use of intermediary devices as a cost-effective option that will fully satisfy an EAS participant’s CAP obligations. These devices, which can later be upgraded or replaced as needed to fulfill one’s obligation to implement the next-generation EAS, are typically less expensive than new equipment that is capable of meeting an EAS participant’s long-term CAP-related obligations. As the commission notes, several manufacturers are already producing such intermediary devices, presumably in response to market demand, with efficient, cost-effective features that provide options for EAS participants to comply with the upcoming EAS rules.
For certain smaller broadcast stations, and stations in small or rural markets with less financial resources, intermediary devices are particularly useful alternatives. [B]roadcasters take pride in their unique role as the backbone of EAS, but the federal obligation to upgrade one’s EAS equipment to a CAP-based system is nevertheless an additional financial challenge that arrives during difficult economic circumstances. Accordingly, any measure of flexibility that the commission can provide in the Part 11 rules that enables broadcasters to better absorb the costs of upgrading EAS equipment, such as intermediary devices, will ultimately enhance the efficient introduction of CAP-enabled equipment. As a practical matter, many broadcasters have already purchased intermediary equipment and it is deployed in the field. Such equipment should be regarded as compliant with commission rules.
Prometheus Radio Project Technical and Training Organizer Margaret Avener wrote:
In the Third Further Notice, the commission seeks comment on whether EAS participants should be allowed to meet their CAP-related obligations through the use of intermediary devices which receive CAP messages and convert them to EAS Protocol. Prometheus recommends that the commission allow the use of such intermediary devices, in conjunction with legacy EAS units, as an alternative to all-in-one CAP-compliant units. Intermediary devices are currently available at prices substantially lower than the cost of all-in-one CAP-compliant units, representing a significant savings to participants.
Gorman-Redlich owner Jim Gorman writes:
EAS participants should be permitted to use intermediary devices which would allow broadcasters to economically meet the CAP1.2 requirement. … CAP converters should be classified as “stand-alone devices” by the FCC and not a modification to a certified encoder-decoder.
… But Certify Them
From Monroe Electronics:
We recommend that the commission extend existing Part 11 certification requirements to any equipment that creates EAS protocol tones from a CAP-formatted message, and that this requirement should apply to both EAS encoder/decoders, as well as intermediary devices. We further recommend that the commission incorporate the IPAWS CAP conformance testing of EAS encoder/decoders, as a complete testing of CAP conformity. However, we caution the commission to reconsider whether IPAWS CAP conformance testing of intermediary devices can be relied upon, since that testing omitted several key portions of the IPAWS CAP profile and [EAS-CAP Industry Group] CAP-EAS Implementation Guide.
Rather, intermediary devices receive CAP messages and actively encode them into EAS protocol format. … By definition, these devices are actually uncertified EAS encoders. There is therefore a critical distinction between equipment that is FCC certified (Part 11 and Part 15 compliant) and intermediary equipment that is performing the same fundamental role, but do not have the required FCC certifications. …
Basically this is a case of uncertified CAP-to-EAS encoders trying to have their cake and eat it too. Uncertified CAP-to-EAS encoders are mimicking the role of an EAS encoder, but circumventing the certification requirement.
Converters Are a ‘Dead-End’; Set Sunset Date for Legacy Gear
Broadcast Warning Working Group, a small group of hands-on EAS experts, writes:
The BWWG has come to believe that allowing vendors to build and market so-called CAP converters may have been a mistake. Legacy EAS first-generation equipment bought in 1996 and installed for 1997 compliance is now 15 years old. There are known problems in legacy EAS vendor products that have embedded printers, keep-alive battery memory, external power supplies and more. Some manufacturers are no longer in business, meaning questionable support for orphaned EAS devices.
While the BWWG knows it may be too late to rectify this mistake, setting a date-certain for retirement of legacy EAS equipment must be done. … No matter what the capability of intermediary CAP converter devices, they all have the effect of “dumbing down” information-rich CAP EAS messages. They are at best a patchwork solution that takes that portion of the EAS user experience down a dead-end road. …
CAP converters will not only delay the inevitable replacement as these devices age more, their manufacturers mislead uninformed buyers into believing that they will be installing a cost-effective solution. EAS equipment buyers should realize that the cost to get completely new CAP-capable equipment is really a long-term wise investment decision.
Certify CAP Converters the Same as a Single CAP/EAS Box
This comment is from Sage Alerting Systems co-founders Gerald LeBow and Harold Price:
Intermediary devices should not have been permitted. … The biggest problem with intermediary devices is that the information available to the device that is actually placing the alert on the air is always only the legacy EAS information. While it is desirable to retain legacy EAS capability for times when CAP is not available, an intermediary device assures that CAP is never available to the device placing the alert on the air. This permanently degrades the performance of the station with an intermediary device in the following ways:
- Legacy devices typically only handle one EAS message in memory at a time. As CAP messages can arrive more quickly than EAS can play them back, a legacy device can drop CAP-originated EAS messages.
- EAS legacy devices have no concept of cancelation. An intermediary/legacy combination will sometimes put cancelled CAP messages on the air.
- The legacy EAS device has no way to receive CAP text from the intermediary device. CAP text is unavailable to video crawl or radio text services equipment if driven by the legacy EAS device.
- Intermediary devices are not currently required to be Part 11 certified.
Sage feels that if a station chooses to use an intermediary/legacy pair to meet its Part 11 requirements, then the pair should be certified to the same standard as a CAP/EAS single box. … Sage recommends that the output of an intermediary device be tested to the same standards as other EAS devices.
Recognize FEMA Equipment Tests
The National Association of Broadcasters also told the commission:
NAB submits that the commission should largely rely on FEMA’s conformance testing for determining whether EAS equipment complies with CAP. … As Sage and others suggest, the commission should merely require that EAS equipment manufacturers file their Supplier’s Declaration of Conformity from the FEMA testing lab as a prerequisite of obtaining commission certification for a CAP-decoding EAS device.Such a process would conserve commission resources, promote interagency coordination, and most importantly, speed the deployment of EAS equipment that complies with both FEMA and commission requirements, for the benefit of the public.
Moreover, the market for CAP-compliant EAS equipment market is far ahead of the now-contemplated Part 11 rule changes. For almost two years, there has been EAS equipment available in the market designed to process CAP-formatted EAS messages, including intermediary equipment capable of accepting CAP EAS messages and translating them to the current SAME format before retransmission.
Many EAS participants have already installed such equipment, based on FEMA’s equipment conformance process. Any additional FCC equipment certification at this point in the process could cause considerable marketplace disruption.
Confirm EAS-CAP Exemptions
Houston Christian Broadcasters Inc., The Moody Bible Institute of Chicago, Augusta Radio Fellowship Institute Inc., Big River Public Broadcasting Corp., Life on the Way Communications Inc. and The Sister Sherry Lynn Foundation Inc. joined on one filing submitted by attorney Jeffrey D. Southmayd of Southmayd & Miller:
The joint petitioners read the commission’s Second Report and Orderto not require noncommercial, educational broadcast stations operated under a “main studio waiver” to be equipped at each satellite station facility with CAP-based alert messaging equipment.
Rather, it appears that the CAP-based alert messaging equipment must only be located at the parent station site with the capability of ensuring that CAP-formatted alert messages entered into the EAS areconverted into and processed in the same way as messages formatted in the EAS protocol at thesatellite stations via equipment at the parent station because such messages are to be generallysent and available through the Internet. However, due to the rural nature of many remotetransmitter sites serving smaller communities, IP availability and capability is limited or absentaltogether. …
Accordingly, the joint petitioners respectfully request that the commission confirm that in the case of noncommercial educational broadcast satellite stations operated pursuant to a “main studio waiver,” the CAP-based alert messaging equipment must only be located at the parent station site with the capability of ensuring that CAP-formatted alert messages entered intothe EAS are converted into and processed in the same way as messages formatted in the EASprotocol at the satellite stations via equipment at the parent station.
Allow No EAS Exemptions
Adrienne Abbott-Gutierrez is a member of the Broadcast Warning Working Group and chair of the State Emergency Communications Committee in Nevada, though she emphasized that she submitted these comments as an individual, reflecting her experience as one of the FCC’s original state chairs, and that they should not be associated with any group or entity.
[The FCC] exempts the so-called “sat-elator” or “hub” stations and radio and television translators from any EAS requirements other than what the originating stations carry. … The problem with the exemptions is that the originating stations for translators and “hub” stations don’t provide emergency information or EAS activations for these remote communities. …
As a result, EAS activations that are heard on translators and “hub” stations are meant for communities hundreds of miles away from the community served by the translator or “hub” station. In some cases, the rural audience is hearing activations that were issued for other states and in different time zones.
This not only can lead to confusion, it means some people simply “tune out” EAS activations and other emergency messages because the information never applies to them. …
With the CAP technology, new EAS equipment could be added to translators or transmitters for “hub” stations and activations could be issued by the local emergency managers for their specific areas without interrupting programming in other communities. The managers of the translators and transmitters would be able to monitor their EAS equipment remotely and perform the necessary record-keeping according to Part 11 requirements.
The FCC should do away with the tables … that allow certain broadcasters to utilize only EAS decoder equipment and instead require everyone to have a fully functional, CAP-compliant EAS encoder-decoder.
Governor’s ‘Must Carry’ Can be Tricky in Border Areas …
Broadcast engineer Gary Timm writes as an individual:
For EAS participants on a state border, the FCC clarifies they are only required to carry messages from “the governor of the state in which the EAS participant is located.” This statement is a good minimum requirement, but perhaps it should read “the governor of the state in which the EAS participant’s city of license is located” to further clarify the meaning.
The commission asked if this definition should be expanded to include “any adjacent states in which the EAS participant provides service,” but then “provides service” must be defined such as by some FCC-defined service contour and it all starts getting complicated very quickly. …
In the end, this is only a minimum requirement and most EAS participants will likely elect to carry messages from all governors in their region on their own. A simple city of license requirement seems adequate to cover the rare EAS participant who only wants to do the minimum, and the rule could add that EAS participants are not prohibited from carrying additional governors in their area.
… And Is Problematic Overall
TFT Senior Vice President Darryl Parker wrote:
There may be at least three methods to facilitate mandatory transmission of messages originated by a state’s governor or designee. All but one involve changes in regulations. All but one depend upon adoption of new state plans before implementation.
One state’s emergency communications coordinator put forth an ideal solution: Educate governors and emergency management personnel in the use of EAS and its benefits and encourage their origination of CAP-encoded messages into a CAP server for their state or area. Education is a large part of the success of emergency alerting. If the system is so complicated that it cannot be used quickly and efficiently to alert the public to emergencies, then the system will ultimately fail. The “Governor’s Must Carry” aspect should be eliminated entirely and rules relating thereto deleted.
Only Governor or Designee Should Originate the Message
NAB writes:
With regard to state-level EAS messages, NAB respectfully reiterates our concern with the delegation of mandatory EAS activations below the gubernatorial level. We continue to believe that only the governor or his/her single designee, as specified in a commission-approved state EAS plan, should be permitted to issue an EAS alert. Granting the power to issue an EAS alert to multiple state officials could lead to unnecessary alerts, public confusion, and possibly public desensitization if multiple alerts are triggered for the same event.
End Required Weekly Tests
Broadcast engineer and RW contributor Thomas Osenkowsky, writing as an individual, states:
The commission has adopted an “as often as necessary to ensure compliance” [policy] with many tests and measurements that previously were required at specified intervals (frequency measurements, remote control calibrations, etc.) The same should be applied to EAS tests. Weekly tests for non-primary stations serve no purpose. No other station is monitoring them for relaying of information.
Monthly tests are a distraction to listeners and if they are continued to be required, should only be relegated to overnight hours. For AM daytimers this is not an issue since the program line is interrupted to transmit the data and message. No primary station is an AM daytimer. Eliminating the requirement would allow states to formulate perhaps an annual test to verify proper equipment operation.
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