FCC Is Asked to Stretch EAS-CAP ‘Clock’

Filers say FEMA, FCC aren’t sufficiently considering delays
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WASHINGTON — A number of broadcasters and equipment manufacturers have told the Federal Communications Commission that more time than currently proposed will be needed to manufacture, deploy, install and test new encoders/decoders for the new, upgraded EAS.

Earlier this year, the commission sought industry input on what changes might be needed to its Part 11 EAS rules to accommodate the Federal Emergency Management Agency’s introduction of the Common Alerting Protocol. CAP is a data interchange protocol developed by the emergency management community and is used to distribute all-hazard safety notifications and emergency warning information.

The comments to FCC Docket 04-296 were due to the FCC June 14. A dozen parties filled initial comments and 10 filed replies covering a range of topics.

In addition to extending the proposed 180-day deadline to have CAP-compliant EAS gear in place by an additional six to 12 months, other common themes emerged.

There was broad support for a national, nationwide EAS test annually. However commenters differed over how much notice participants should have before the test. Most disagreed with the FCC over how much data from those tests should be reported to the commission, and whether and how much of that information should be made public. There was support for suspending EAS enforcement during the national test as well.

Several said the federal government should fund EAS training for state and local governmental EAS message originators to understand the next-gen alerting system, as well as for stations, to encourage more participation in alerting.

Many supported adoption of a CAP-to-EAS implementation guide developed by a coalition of equipment manufacturers, software/service providers and broadcasters, and recommended that either the FCC or FEMA adopt the guide; see www.eas-cap.org.

Here are excerpts of some of the more noteworthy comments.



Extend Time for Stations to Install New EAS Gear

Several executives contributed to the NAB filing. Topping the list was Jane Mago, its executive vice president of legal and regulatory affairs, who wrote:

FEMA may not announce the final details of the CAP standards until close to its publication of those standards in September 2010. Vendors will need sufficient time to incorporate those details into their software products before design of the products can be finalized. …

Manufacturers will need to perform tests on the end products of their design, including conformance testing at a certified lab to obtain commission certification. … Accordingly, NAB encourages the commission to reconsider the existing 180-day deadline for EAS participants to accept CAP-based messages, as it may be inadequate to allow a smooth transition to next-generation EAS.

The commission should inject flexibility into this obligation, either by extending the timeline to a full year, or perhaps resetting the trigger for the 180-day timeline to an event other than FEMA’s publication of CAP standards, such as a finding that tested and certified CAP-compliant products are abundantly available in the market for purchase and installation by EAS participants.

Jim Heminway, president of Monroe Electronics, told the FCC:

Launching such a new and technically involved architecture is sure to hit snags. This is an unnecessary time period. The system will not work better simply because we desire it to be implemented faster. Better to do this systematically and correctly, allowing time for a smooth transition. … Many of our customers will not put any product, not just EAS, into their systems until it has gone through their testing and approval. This includes both software and hardware. This alone may take up to 180 days.

From TFT Inc. and its SVP Darryl Parker:

The limited number of manufacturers available to produce this type of equipment may … inhibit implementation of this 180-day deadline. With approximately 30,000 EAS participants and relatively small sized manufacturers with limited production capabilities, the design-approval-purchase-delivery-installation cycle could run well beyond 180 days.

Once approved equipment is delivered by a manufacturer to an EAS participant, personnel will necessarily need time to install, test and train. Another difficulty in installation of CAP decoding equipment will be Internet connections and availability of CAP servers with emergency information for a particular EAS participant’s area of influence. Not all locations with EAS encoder/decoders or decoders (only) have access to the Internet. Facilities, sometimes at additional expense, may have to be constructed by third-parties under contract to EAS participants.



Opposed to Clock Extension

This comment is from Sage Alerting Systems co-founders Gerald LeBow and Harold Price:

Some comments, both in these proceedings and in public forums, have implied that the industry is not ready to produce equipment, and that a period of research and development must begin after FEMA’s announcement of its acceptance of the various definition documents. This is not the case.

CAP 1.1, and the modest changes in the CAP 1.2 specification, as well as the IPAWS Profile 1.0, have been known since last year. Indeed, the EAS-CAP Industry Group used these documents as the basis for its recommendations for a CAP EAS Implementation Guide. Implementations of CAP 1.2 exist. …

Another argument is that industry will not be able to produce the necessary hardware, and a delay in the start of the clock is needed. Speaking for Sage, we have been producing the hardware and software since 2008. … Sage does not plan to build thousands of units, place them in the warehouse, then sit back and hope for the best. Sage will maintain a reasonable inventory, and build as orders arrive. There is no advantage to delaying the start of the clock from our point of view — no manufacturer is going to stockpile large quantities of product in advance of need.

By broadcast engineer Gary Timm, a prominent participant in national EAS discussions:

I agree with Sage. … It is very important that EAS participants not be allowed to lag in their equipment upgrades, so any system improvements made by FEMA can be ensured to be installed by all EAS participants within a defined window.



Several Distribution Methods Needed

Jim Heminway of Monroe Electronics also wrote:

The broadcast daisy chain method of EAS distribution, while having limitations, has served us well. It has the ability to deliver alert audio information in detail, yet in its current form severely limits the amount of text information that is available.

For audio-only forms of communication this is not an issue. However, those communication technologies that provide visual alerts … are unable to provide important detailed alert information. This becomes especially critical in systems where only text is provided (i.e., digital signage and cell phone text messages) and to people who are hearing impaired. …

While we have delineated some of the deficiencies in the current broadcast distribution system, we believe it is a valuable redundancy to the proposed next-generation system and should be maintained. In most natural disasters the broadcast medium is the last system standing and is unparalleled in the “one-to-many” message distribution.

Relying on any one method, such as IP, is not in the nation’s interest. We believe strongly that the new Part 11 rules define acceptability of a multimodal distribution architecture that includes broadcast, IP, datacast and satellite. This allows states to employ such technologies as they may require or already have in place.



Feds Should Fund Training for Alert Originators

This comment is from Texas Association of Broadcasters President Ann Arnold:

Tragically, we have found too many situations in Texas and in other parts of the nation where local authorities do not even know what EAS is, much less how to take advantage of this unique tool to warn citizens of approaching wildfires or other life threatening challenges.

So as our first recommendation for rules changes to accommodate EAS, we recommend specific strategies be adopted to educate officials at all levels of government about the benefits available under the new Common Alerting Protocol and steps be taken to make sure they actually are utilized.

Eventually authority should be requested from Congress to make utilization of CAP a requirement for state and local governments to continue to receive federal funds for disaster planning and damage mitigation. Optimally, training should be offered at the federal, state and local levels to make sure officials not only know of the existence of EAS but, also how to use it to save lives and protect property.



… and to Encourage States to Adopt Next-Gen EAS

From Gary Timm:

I agree with the comments of Ann Arnold of the Texas Association of Broadcasters that federal funding is needed to encourage states to update to next generation EAS. I would add that a problem some states are having with the current FEMA grants that can be applied to EAS improvements is that FEMA will award those grants only to state and local government agencies.

While that may work in some locations to get funding for EAS needs, as Ann Arnold points out some states such as hers do not have an EAS-engaged state government. Thus such states will never pass on these FEMA grant monies to SECCs or others to carry on EAS improvements. The FCC needs to either establish funding itself, or needs to work with FEMA to open up their grants, to allow SECCs and other crucial non-government entities to access any monies that are intended for EAS improvement.



SBE: National ‘Test’ Should Be Called ‘Exercise’

Also commenting was the Society of Broadcast Engineers, with President Vincent Lopez and General Counsel Christopher Imlay:

The SBE is supportive of national EAS tests. The utility of EAS has been questioned from time to time by some in the broadcast industry, and successful national tests may quell some of that controversy. …

SBE recognizes that effective EAS performance necessitates scrupulous compliance by broadcasters with certain EAS regulatory requirements and careful attention to accurate monthly EAS tests, etc. However, the commission’s history of zealous enforcement in this area, and the fact that EAS tests have been a frequent source of monetary forfeitures for the commission’s Enforcement Bureau, serve as a discouragement to broadcast station participation in EAS.

For these reasons, SBE recommends that national EAS tests should be viewed by the industry, and the commission should treat them, as national “exercises,” rather than as “tests.” The emphasis should be on encouraging participation, and as a public/private “partnership” of entities involved in a program for the common good, not as a program that will result in commission sanctions for relatively minor errors or omissions by participants acting in good faith. …



Rein in Reporting Requirements

Cox Media Group and attorney Scott S. Patrick of Dow Lohnes wrote:

Cox opposes the proposed reporting provisions as being unnecessary for an effective and properly functioning EAS. … Routine equipment testing by broadcasters is sufficient to ensure the public receives alert and warning messages in an accurate and timely fashion. … To the extent the commission nonetheless wishes to adopt some type of formal reporting requirement, Cox believes such reporting should be web-based and limited to those EAS participants whose particular tests reveal some type of anomaly.

Cox also has concerns about the commission’s proposal to make public numerous details of the operations of EAS participants. The commission has acknowledged in the past that it must keep EAS secure and impervious to malicious activities and threats. Given the importance of EAS as a means of quickly providing accurate information to the public, any attacks on or unauthorized use of EAS could be devastating. Cox accordingly urges the commission to account for security issues when weighing the benefits of publicizing EAS operational details.



An IP-Based System Is Not the Answer

Broadcast engineer Michael G. McCarthy told the FCC:

[M]any ground-level folks charged with implementing CAP/EAS-II in broadcast and cable operations carry grave concerns regarding IP message relay and retrieval robustness. … CAP’s reliance on the public and station/facility wired IP infrastructure is fraught with fragile and unrecoverable weak links. …

And then there is the all-too-common radio station out on the forgotten rural road served by 40-year-old copper through 100 aged and infested splice pedestals. … In many operations, that weakest link is exhibited by an end user (least-cost) DSL or T-1 circuit riding a conventional [Bell Operating Company] 40-year-old last mile POTS copper pair fed from an underground service expansion terminal. …

The bottom line is simple: Aside from the fact CAP-compliant EAS-II is an unfunded mandate imposed on the stakes holders, message dissemination, access and retrieval by the public web and station IP infrastructure is a distribution linking system predisposed to fail in any type of local, regional, or national crisis. … Radio systems can be hardened quite effectively. Unlike wired IP, radio (analog or UPD) survives catastrophic events with little remedial attention if the infrastructure is so hardened.



Conduct ‘Pre-Test’ First

Maine State Emergency Communications Committee Chair Suzanne Goucher offered this:

The commission raises questions about the capability of various manufacturers’ ENDECs to process [Emergency Action Notification] messages, and queries whether the difference in how ENDECs are programmed could “impact the relay of an EAN test message during a national EAS test.” One simple way to answer these questions would be for the commission to conduct a closed-circuit test of all ENDECs currently available on the market, prior to conducting a national test.

This would give ENDEC manufacturers and programmers an opportunity to address any hardware or software issues that arise, regardless of the code used, and would allow them to notify EAS participants of any needed upgrades. Presumably, ENDEC manufacturers have a vested interest in ensuring that their equipment functions properly … so it can be surmised that they would welcome the opportunity to test their equipment in controlled circumstances in order to ensure proper operation.

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