A group of suppliers of EAS-CAP gear and services is asking the FCC to reconsider a decision it made in its recent EAS report and order.
Signing were Sage Alerting Systems, iBiquity Digital, TFT, Monroe Electronics/Digital Alert Systems, Alerting Solutions Inc., MyStateUSA, Communications Laboratories Inc. (Comlabs) and Warning Systems Inc.
These are members of the EAS-CAP Industry Group, or ECIG. They are concerned about the FCC’s prohibition of text-to-speech on CAP receiving equipment, as well as details of CAP-EAS equipment certification requirements. The companies said their comments “represent a consensus on these key issues, taken from very diverse range of perspectives.”
While saluting the FCC for its efforts in EAS, they warned of “very significant and potentially adverse implications” that would result from the decision to disallow use of text-to-speech technology in CAP receivers. The impact on EAS participants and originators, they wrote, may be “profound.” The rule would remove important backup capability in case an audio file created by the originator is missing or damaged.
Without text-to-speech, and should there be no audio file, the audio output would consist of only header tones followed by end-of-message tones. There would be no voice component. For broadcast radio, this would mean only the header tones, Attention Signal3 and EOM tones are heard. “This would, of course, have a severe impact on the usefulness of the alert message for overall listening population. Listeners may know that there is an emergency situation … but they will have no information about the nature of the emergency. The potential for widespread confusion and/or disregard for the EAS could be the result.” Visual media would also have audio components impaired.
CAP EAS originators, including FEMA itself, may be affected too, because the IPAWS system uses text-to-speech translation technology at the CAP receiver. The National Weather Service CAP feed also relies on text to speech. “Apparently NWS may not necessarily and consistently create audio files for download construction of EAS protocol messages by these devices.”
The FCC decision also could hurt state aggregator and distribution systems that are in place or underway. Dissemination systems might need changes that would cost local agencies money that isn’t available. And there could be unforeseen consequences for people with disabilities.
The suppliers also talked about the commission’s efforts to streamline the certification process for CAP EAS devices. Among other things they asked that the FCC not permit self-certification. They asked the FCC explicitly to incorporate language regarding “intermediary devices” into its rule appendix, and asked for clarification on how intermediary devices are covered by the commission’s Part 11 testing regime.
They also urged the FCC to push ahead with setting up the streamlined certification process, but acknowledged that FEMA must issue test guidance procedures and parameters first. And it offered specific suggestions about how certification should be handled.
Read the ECIG letter here (PDF).