The National Association of Broadcasters says the FCC’s ongoing “ground-up” review of EAS should not dismiss the system’s strongest existing link: local broadcast stations.
The commission’s notice of proposed rulemaking released in August has been collecting public input on ways to expand EAS and make the system more effective.
The NPRM asked questions about EAS and WEA and whether they meet the needs of the public and alerting authorities. It asked about the objectives that effective alert and warnings systems should serve.
Earlier, as we reported, the NAB laid out ways it believes EAS could be improved, which includes geotargeting, funding for training alert originators and better compatibility for severe weather alerts (read about that here).
In its reply comments last week, NAB focuses mostly on reinforcing its argument that the architecture of broadcasting makes radio and TV stations uniquely reliable during emergencies and that the backbone of the system should be maintained.
The association calls broadcast-based alerting the “gold standard for resiliency and reliability.” It took exception to an assertion by the Consumer Technology Association that broadcast-based EAS is not a critical part of the alerting ecosystem. NAB calls CTA’s comments “uninformed and disingenuous.”
[Related: “CTA on Emergency Alert System: If It Ain’t Broke Don’t Fix It”]
To support its argument, the NAB points to instances where cell networks failed at the most inopportune times, such as during Hurricane Helene, when 90 percent or more of the cell sites in North Carolina were out of service, and Hurricane Ida, when similar failures struck several counties in Louisiana.
NAB says it supports technical innovation for EAS and that concepts in the notice deserve further consideration, but it said any improvements adopted by the FCC should be treated as optional and should not impose more mandates or costs on current EAS participants.
“This approach will allow implementation of any EAS changes to be tailored to a specific communications sector, whether broadcast, cable or perhaps new platforms, as well as to the circumstances and resources of individual EAS participants,” NAB wrote.
“Such an approach is also consistent with NAB’s support for technical innovations that will enhance the effectiveness of the existing system, such as our proposal to allow EAS participants to use a software-based encoder/decoder, which is explicitly intended as a voluntary option for EAS participants.”
The FCC’s notice raised the prospect of extending emergency alerting to additional platforms, such as streaming services, social media and personal computers. NAB told the FCC that the record reflects disagreement about this.
Several emergency management authorities support the idea, NAB wrote, but on the other hand, “CTA claims that expanding alerting to end user devices is unnecessary because wireless emergency alerts already reach the public sufficiently.”
If the FCC wants to expand EAS beyond its broadcast roots, the NAB called for a collaborative process. It suggests that the FCC form an advisory committee to consider certain concepts raised in its notice.
“NAB joins with commenters urging the FCC to establish a public-private advisory committee of experts to study some of the thorny questions posed in the notice.”
The filing also mentions comments from Digital Alert Systems that recommended relying on the expertise of groups like FEMA’s IPAWS Subcommittee and the FCC’s Communications Security, Reliability and Interoperability Council, and reinstating the FCC’s National Advisory Committee.
The NAB concluded by acknowledging that it and most commenters agree that allowing non-government entities to trigger alerts is a non-starter. “Stakeholders are rightly concerned about over-alerting.”
The federal government shutdown delayed the reply comment filing window in the FCC’s EAS proceeding (PS Docket 25-224). Access filed comments here.
