This story continues our coverage of industry debate over NAB’s petition asking the FCC to allow stations to use software-based EAS encoding and decoding, a debate that took a more strident and emotional tone this week.
Here we summarize reply comments from Digital Alert Systems and Sage Alerting Systems.
NAB wants the FCC to give broadcasters the option to replace encoding/decoding hardware with software hosted by one or more hardware elements. These elements could be housed at the studio, transmitter site or perhaps in multiple installations, adding redundancy, NAB says.
Digital Alert Systems
DAS now is the sole active manufacturer of EAS encoder/decoder hardware. It has urged the FCC to take a more cautious approach and has described the NAB petition as “premature and procedurally inappropriate as the basis for a rulemaking.”
NAB this week criticized DAS in strong terms about its opposition, as we reported, stating among other things that DAS was acting out of self-interest and that its concerns were overblown.
Now in its own reply comments, DAS said NAB’s characterization of it being the “lone, self-interested objector was unfortunate” and distracts from legitimate, technical and operational concerns.
“Rather than engaging with the specifics of Digital Alert Systems’ questions, it was disappointing to see ad hominem insinuations about market motivation and attempts to dismiss critical input as obstructionist. This approach undermines a productive and evidence-based policy,” DAS told the FCC.
“Digital Alert Systems is not voicing questions and concerns out of market preservation, but out of concern for operational integrity, security and the reliability of the Emergency Alert System.”
DAS says its real-world experience with software-based EAS solutions drives its call for a “informed, collaborative rulemaking.”
The NAB in its comments this week told the FCC that when it approached Sage and DAS in 2021 to discuss the concert of software-based ENDEC, only Sage engaged constructively.
DAS disputed with that assertion, calling it flawed.
“Agreement from one vendor does not negate the validity of technical concerns raised by another. A multi-stakeholder system like EAS demands that ‘dissenting’ views — particularly from technically proficient actors — be considered thoughtfully rather than dismissed summarily.”
The equipment manufacturer also criticized NAB for saying the company is the lone dissenting voice.
“We note that the Broadcast Warning Working Group (BWWG), which includes chairs and participants from at least three State EAS Committees, has voiced similar questions and concerns,” DAS wrote.
The BWWG said one of its biggest concerns is that the NAB petition was developed without consultation with the State Emergency Communications Committees or a broader broadcast engineering and EAS participant communities. The BWWG filing was signed by Barry Mishkind and Richard Rudman.
In its comments, DAS said that NAB was positioning it as a “hardware dinosaur” with an outdated or cumbersome platform but called this a “strawman” argument that is misleading and incorrect.
“Digital Alert Systems’ hybrid solutions incorporate modern software capabilities, remote access features and API integration — offering broadcasters the very flexibility NAB seeks, while still preserving the deterministic reliability of dedicated hardware for emergency scenarios,” DAS wrote.
In fact, it said that contrary to NAB’s implication, DAS is not opposed to exploring the concept of a software-based EAS architecture. However, DAS says it has encountered what amounts to a zero-sum, “our way or the highway” posture.
DAS has advocated a hybrid virtual system that would require a hardware device but bring the emergency alert process into the interconnected AoIP ecosystem. The company believes that modern EAS devices are technically superior to proposed software substitutes.
In its conclusion, DAS says its so-called “dissent” should be viewed as an opportunity to strengthen the proposal. Its input “is not a roadblock — it is seeking guardrails, attempting to define requirements, and ensuring that modernization does not come at the expense of security, reliability and regulatory clarity,” it wrote.
“The process must be conducted with full, transparent and technical engagement with all stakeholders, not with a dismissal of valid concerns as mere commercial protectionism.” And it says it “remains open and committed to a professional, good-faith dialogue with all stakeholders on this important matter.”
Sage Alerting Systems
Sage EAS hardware is widely used in radio but Sage discontinued manufacturing those products last year.
In its own reply comments, Sage continued to express its support of NAB’s proposal.
“EAS is often the only remaining special case, requiring special audio and control paths, in a modern facility. At its heart, the NAB petition is an attempt to allow the industry to remove EAS as a special case — allowing users and suppliers to craft solutions that align with modern realities,” it wrote.
Sage says most of the FCC’s encoder and decoder rules are from 1994, and that the environmental, electrical and audio requirements required then are common in equipment used today. “Other requirements for specific inputs and outputs are not needed in a digital audio over LAN [Local Area Network] environment,” it said.
Sage addressed the perceived need to continue to require certified hardware: “Integral displays are not needed in an unattended facility or an attended facility that uses a LAN for device control. These old requirements add to the minimum cost of a specialty hardware device. Some users may want the features, but there is no need to force them on everyone,” Sage wrote.
Sage calls for a set of tests similar to the 2011 FEMA Conformity Assessment. It argues that the broadcast industry should work towards a more sustainable EAS future that includes simplifying hardware requirements and potentially eliminating them.
