The FCC clearly has been giving a lot of thought to the state of the Emergency Alert System.
The commission spent much of 2021 reviewing EAS for ways to tweak it, as mandated by Congress; and it has taken some steps, such as requiring State Emergency Communications Committees to meet at least annually and to submit plans for FCC approval. It is exploring other ideas such as internet alerting, as we’ve reported.
Another Notice of Proposed Rulemaking, opened at the FCC’s December meeting, deals mainly with video accessibility but has some radio implications. And a companion Notice of Inquiry asks about further changes that could affect EAS and radio much more broadly.
The EAS system consists of both the legacy broadcast infrastructure as well as an internet-based Common Alerting Protocol structure, which has better visual messaging capabilities.
In its NPRM, the FCC proposes first to clarify the visual crawl for legacy-based nationwide EAS tests — like the National Periodic test last August — by requiring TV stations and other video service EAS participants to use scripted text as opposed to constructing the visual crawl from the header code.
The crawl text would be “This is a nationwide test of the Emergency Alert System issued by the Federal Emergency Management Agency covering the United States from [time] to [time]. This is only a test. No action is required by the public.”
In its notice the FCC asks a series of questions about that proposal, including whether for reasons of consistency it should also apply to CAP-based nationwide EAS tests, or whether doing so would limit the flexibility of CAP alerts.
The commission then also proposes to change the terminology for the nationwide test event code or NPT from “National Periodic Test” to “Nationwide Test of the Emergency Alert System.” The NPT code itself would stay the same but the name seen by the public would be clearer.
The commission pointed out that FEMA separately has recommended a change in terminology for the PEP originator code from “Primary Entry Point system” to “National Authority.”
[Related: The FCC Studies Internet EAS Alerting]
If both of these changes were adopted, the FCC said, the minimum required information in a CAP-based nationwide test visual crawl would change from “The Primary Entry Point system has issued a National Periodic Test for the United States beginning at [time] and ending at [time]” to “The National Authority has issued a Nationwide Test of the Emergency Alert System for the United States beginning at [time] and ending at [time].”
It wants to know, among other things, if these changes will make the visual message for CAP-based nationwide EAS tests more understandable and informative, or if other language would be clearer.
All of the above is aimed at video service providers but sets the stage for consideration of additional changes with more relevance to radio.
The second major proposed step in the NPRM is to require EAS participants, including radio stations, to “poll” IPAWS, the Integrated Public Alert and Warning System when they receive a legacy-based state or local area EAS alert, to confirm whether there was a CAP version available, and to process that alert instead. National Weather Service alerts would be included in this requirement. (NWS alerts are not currently sent on the IPAWS EAS feed.)
The goal is to promote the use of CAP and its capacity to provide matching visual and audio messages.
The FCC noted that EAS participants typically receive legacy and CAP versions of an alert at different times, and the rules don’t specify which version gets delivered. The rules do allow participants to check for CAP versions of state and local legacy EAS alerts but they don’t require it. Unless a station has programmed its equipment to check for a CAP version when it gets a legacy version, the equipment will process whichever is received first.
But CAP allows alert originators to relay enhanced text that can transcribe full audio messages, allowing visual messages that can match longer audio messages. And the FCC believes that any encouragement of the use of CAP versions is beneficial, because those alerts have more information, potentially including visual and audio messages that match.
The commission asks for feedback on that proposal, including whether it could be achieved via a software update and whether there are other ways to facilitate the use of CAP by alert originators with enhanced text that transcribes the verbiage in the audio message.
The FCC isn’t proposing to extend this proposed CAP prioritization mandate to nationwide EAS tests, which often are used to test performance in distributing a presidential EAN message under circumstances where only legacy EAS is available. But it did ask for comment on whether it should do so.
It also asks whether EAS participants should be allowed some minimum timeframe when polling IPAWS before determining that no CAP version is available. And it asked if its CAP prioritization proposal should include required monthly and weekly tests.
Along with the NPRM proposals described above, the FCC issued a notice of inquiry, asking for comment on more steps that could improve the accessibility and utility of EAS. The commission uses NOIs as a way to create a dialogue about longer-term questions and possibilities that are not immediately on the table.
Again, much of the NOI’s discussion was about video yet it overlaps with radio interests.
The FCC points out that EAS is an audio-based system and that the legacy portion of the infrastructure was not designed with visual display of text in mind.
In legacy-based alerts, originators currently can generate an audio message that verbalizes the header code elements used to generate the visual message, so that the visual and audio messages match. But this approach may leave unused some of the two-minute allotment for the audio message. That extra time could be used to convey important information. But fully using the two minutes could mean that the visual information will not match the audio portion of the alert.
[Related: Carriers Report Success in National WEA Test]
So in the NOI, the commission asks whether legacy EAS should be modified to enable the distribution of enough text to transcribe the entirety of a two-minute audio message. This raises a technical question.
It notes that the legacy EAS uses AFSK modulation to convert data into audible tones, a process considered cumbersome. Using it to relay sufficient text to match the verbiage in a two-minute audio message theoretically would result in a tone that is roughly 30 seconds in length.
EAS participants have feared that longer alert tones could send listeners searching for the “off” button, or perhaps moving over to streaming providers, where there are no alerts (at least at present).
So the FCC asks: Would the public — not to mention radio and TV stations and other EAS participants — tolerate such a tone? Is there a better compression or modulation scheme that would deliver the necessary information, functioning across all EAS participant services and delivering live audio and maybe video? Is there a role for digital transmission standards such as ATSC 3.0 or HD Radio to improve EAS capabilities?
And last, the commission really goes broad.
It asks: Rather than focusing on ways to modify legacy EAS to relay text or CAP, would it make sense to use legacy EAS only for the Emergency Action Notification (EAN) and NPT, but require use of CAP for all other alerts?
And if legacy EAS can’t be reasonably modified to allow alert originators to distribute text to transcribe a two-minute audio message, should the legacy EAS architecture be redesigned altogether?
The commission noted that in 2012, when it adopted CAP EAS rules, it kept the legacy EAS because of its resiliency in the face of a national emergency and because there was no fully CAP-centric system in place to replace it. It now asks whether those factors “remain as true and relevant today,” and whether EAS could be redesigned to keep the resiliency and automation of legacy EAS but with the functionalities of CAP.
We asked some EAS observers for reaction to all of the above.
Harold Price, president of manufacturer Sage Alerting Systems, said requiring stations to poll the IPAWS server as described in the NPRM is an “automatic seek-and-fetch of the CAP message when the broadcast EAS version is received first.” He said it raises the possibility of delays, including timeouts of alerts and message duplication errors.
“It is possible the legacy message will be generated and transmitted via a state relay system before it is sent to or processed by IPAWS.”
However, he continued, the requirement could result in better audio quality.
On the question of whether the legacy EAS might be redesigned to enable distribution of text sufficient to transcribe a two-minute audio message, Price and some others expressed doubt.
“There is little chance of improving EAS by stuffing long multilingual text strings down a 65-character-per-second pipe,” he said.
Ed Czarnecki, vice president of global and government affairs for manufacturer Digital Alerting Systems, said, “The existing protocol enables us to create that short standard EAS message. The question is whether and how EAS can support more text. I think it’s safe to say that nobody desires a solution that results in overly long tone bursts over the airwaves to carry all that text.”
Czarnecki noted the proposed change of the PEP originator code to “National Authority” instead of “Primary Entry Point.”
“A software update for all EAS devices could handle this. If adopted, I’d hope that this proposal will provide enough time to allow for such a change to be slid into a minor software update.”
Czarnecki said the NPRM asks several questions that may pose issues for the radio industry. “For example, they ask whether it makes sense to only use legacy EAS for the EAN and NPT and rely on internet CAP for all other alerts, which could signal a less relevant position for radio broadcasting in general.”
He also noted that the FCC didn’t exempt radio stations from the proposal that EAS participants poll IPAWS.
“I think there is some good logic behind this. One benefit would be giving radio stations with access to first-generation CAP audio, when available, compared to second- or even third-generation audio from a conventional EAS message,” he said.
“Another indirect benefit for radio stations with newsrooms is that the expanded CAP text may also provide more detail and a fuller ‘story’ than conventional EAS messages.”
He said the company’s DASDEC equipment already has the capability, which it calls Triggered Cap Polling.
“Another use case for the FCC’s proposal comes to mind: multilingual,” he said. “If a multilingual CAP message is available, the use of Triggered CAP Polling would prompt a station to seek out that CAP message and use its contents instead. That content could include optional additional languages, in the case of a Spanish radio broadcaster, or any other provided language.”
Czarnecki does not agree with the idea to use legacy EAS only for the Emergency Action Notification (EAN) and NPT and require use of CAP for all other alerts.
“We’ve noted many times, including in our own filings with the FCC, that legacy EAS provides a resilient backup system when CAP over internet is unavailable for any reason.”
He cautions, “The reliability of our public warning architecture could be dangerously compromised if the FCC allows CAP-only monitoring without radio-based EAS at least as a backup.”
He said EAS manufacturers also have reservations about the FCC’s question about whether the legacy EAS architecture should be redesigned altogether.
“Triggered CAP Polling adequately addresses this question. The full text can be contained in a CAP message. If EAS is received first, that triggers the EAS device to poll IPAWS for CAP, and uses that message instead. If CAP or the internet is not available in an extreme situation, then at least the basic EAS message can be issued.”
Manufacturers believe there may be ways that EAS can be improved without a costly architecture redesign. However, the feeling is that discussion within industry might be more appropriate at this stage.
Czarnecki said, “The questions posed in the NOI are appreciated in that they are far-reaching. We’re hoping to confer with other EAS manufacturers about various technical issues that these questions raise.”
Comment deadlines had not been set as of mid-January.