EMERGENCY ALERT SYSTEM  Request for Comments


The Emergency Alert System (EAS) was established to provide the President with a method for addressing the nation during times of national crisis. Although it has never been used for this purpose, the EAS is frequently used by local, state and federal officials to warn citizens during times of emergency - both natural and manmade.  Today, the EAS is one of two national systems used to warn the public during times of emergency.

The Partnership for Public Warning (PPW) has conducted an assessment of the Emergency Alert System (PPW Report 2003-3, available at www.PartnershipforPublicWarning.org).  This report provides a history of the EAS, describes its current operation, and identifies key issues affecting the systems' effectiveness.  As the report indicates, the current Emergency Alert System has policy, management and operational challenges.

The working group that prepared the EAS assessment has developed a number of recommendations for improving the reach and effectiveness of the EAS. The Board of Trustees of the PPW has approved the assessment for final release but has not yet adopted the recommendations.  Prior to taking action on these recommendations, the PPW Board of Trustees wishes to obtain public comments on the proposed recommendations.

The Partnership for Public Warning is a 501(c)3 non-profit consortium chartered in January 2002 for the purpose of improving the nation's ability to alert, warn and communicate with the public during times of emergency. PPW provides an objective, consensus-based forum where government, industry, non-profits and academia are working together on standards, policies, education and systems.

PPW has issued "A National Strategy for Integrated Public Warning Policy and Capability" (PPW Report 2003-1) that identifies the key issues that need to be addressed in developing a more effective national public warning capability.   As set forth in the national strategy, an effective national public alert and warning capability should provide timely and effective warnings to people regardless of their location, the time of day or the language they speak.  Achieving this objective requires an integrated capability that utilizes multiple distribution technologies.  EAS can be part of this solution, but it is not the entire solution.  For more on the development of a national public alert and warning capability, see the PPW strategy and its implementation plan, "Implementing the Vision", (PPW Report 2003-4).  Both reports are available on the PPW web site.

Proposed EAS Recommendations

A working group sponsored by the Partnership for Public Warning has developed the following issues and recommendations for the Emergency Alert System.  Public comments are now requested on these recommendations.  At the conclusion of the public comment period, the recommendations will be presented to the PPW Board of Trustees for appropriate action.

Commentors are invited to address the recommendations listed below but are not limited to these recommendations.  Issues and recommendations not addressed herein may also be addressed at the discretion of the commenter. All issues and recommendations identified during the public comment period will be provided to the PPW Board of Trustees.  It is expected that the PPW Board of Trustees will take action on the recommendations during its meeting of December 10, 2003.

Comments should be submitted to the Partnership for Public Warning no later than 5:00 PM (EST) on November 28, 2003.  Comments may be submitted via the Email Forum on the PPW web site (use the EAS topic at http://www.ppw.us/jive/index.jsp) or by emailing the comments to information@ppw.us.

Questions regarding this matter may be forwarded to the Partnership for Public Warning at information@ppw.us.

ISSUE 1: Broadcasters and cable operators are not required to transmit EAS state and local warnings.

Broadcasters and cable operators are presently only required to transmit EAS national level (Presidential) messages and the required EAS weekly and monthly tests specified in the FCC Part 11 EAS regulations. The tests are required to ensure EAS equipment readiness. The FCC does encourage broadcasters and cable operators to carry EAS state and local warnings and this is emphasized at EAS workshops. In addition, FCC regulations do allow for the transmission of EAS warnings in lieu of the required EAS tests. However, there are no real incentives to transmit the warnings.

Recommendation 1:

The government should implement more meaningful incentives to get broadcasters and cable operators to transmit EAS state and local warnings. The FCC should study the incentive issue. It should also keep records of EAS activations to determine where the system is operating effectively and ineffectively. The National Weather Service (NWS) presently develops service assessment reports to determine how well NWS performed during major disasters. The government should also develop similar reports to determine how well EAS performed in disasters.

ISSUE 2:         EAS has critical missing communications links.

At the national level, the communications link between the federal government and the Primary Entry Point (PEP) stations relies on the Public Switched Telephone Network (PSTN). In addition, the PEP system of broadcast stations cannot be reliably monitored by all of the state EAS systems. Therefore, a very large number of the 14,000+ broadcast stations and 10,000+ cable systems will not receive an EAS national level (Presidential) message.

At the state and local levels, many emergency managers do not have communications links to the key EAS sources or the National Weather Service's NOAA Weather Radio (NWR). This causes unacceptable delays in getting emergency information to the public.

Recommendation 2:

At the national level, the PEP communications link needs to be upgraded to either a dedicated circuit or another more robust transmission medium. The PEP system needs to add stations and the major broadcast networks and national cable program suppliers to expand its reach. In the past, the Federal Emergency Management Agency (FEMA) and the FCC took the lead in an effort to enlist the networks to participate. National Public Radio (NPR) is presently voluntarily participating in the national level EAS by operating EAS equipment that monitors a PEP station and by transmitting weekly EAS tests on one of its national satellite channels. To ensure that the PEP system is in a ready state, weekly closed circuit tests of the PEP system need to be expanded to include some on air tests. This can be accomplished in such a way so that there is very minimal disruption to the PEP stations' programming.

At the state and local levels, resources are needed to provide communications links including designating government radio channels for local relay networks. Also, a nationwide needs assessment for equipment and connectivity to connect local origination points with EAS entry points is required to determine the existing structure. This will pinpoint those areas where immediate improvement is necessary.

ISSUE 3:         Very few of the 3,000+ U.S. counties have EAS equipment.

Without EAS equipment, county emergency managers must rely on contacting broadcast personnel to get emergency information into the EAS system. Since many broadcast stations operate a portion of the day and almost all of the night unattended, it is sometimes impossible to contact broadcast personnel. Also, some of the broadcast personnel are unfamiliar with operating EAS equipment. Broadcast and cable operations are much more suited to relaying EAS messages than originating them.

Recommendation 3:

Resources are needed to equip emergency managers with EAS equipment and the communication links specified in 2 above. Only then will they be able to originate and transmit EAS messages for relay by broadcast stations and cable systems, even if the stations and systems are unattended. This is even more important if Amber plans are going to be successful. There is precedent for funding programs that provide equipment to the broadcast and cable industries. The Broadcast Station Protection Program is one. The other was a program that was funded by FEMA in the early 1980s. It assisted cable systems with installing cable override equipment so that local officials could send emergency information on all channels on cable systems. Cable override equipment for all cable systems eventually became mandatory through implementation of the 1992 Cable Act and the FCC Part 11 EAS regulations.

ISSUE 4:         EAS planning has fallen behind.

Many of the existing EAS state and local plans need updating and some have never been finished. The list of EAS plans in Appendix D of the EAS Assessment Report shows that 26 plans are at least five years old since they were developed in 1998 or earlier. The State Emergency Communications Committees (SECCs) and the Local Emergency Communications Committees (LECCs) have performed sterling service over the years with very limited resources. Industry associations have tried to help by providing assistance. The Society of Broadcast Engineers (SBE) and the Society of Cable Telecommunications Engineers (SCTE) have developed and distributed EAS training documents and videos and provided web sites for the exchange of EAS information. The Federal government provides some assistance. The FCC maintains an EAS web site that contains EAS information and the EAS Handbooks at www.fcc.gov/eb/eas . In the 1990s, FEMA developed two draft EAS Civil Preparedness Guides (CPGs).

Recommendation 4:

The FCC, FEMA and NWS (or one Federal agency) need to take charge of EAS and to assist the SECCs and the LECCs. While the above efforts are helpful, they need to be supplemented with on-site training of state and local personnel, the development of an EAS study course, and regular participation by officials in EAS tests. The agencies need to commit resources to conduct EAS planning workshops at the state and local levels. The volunteers cannot do it alone. All of the EAS state and 500+ local plans need to be finalized with regular tests involving all participating personnel. The plans need to be standardized in such a manner that they incorporate certain required planning elements, conform to the EAS regulations in Part 11, and enhance the national level EAS. The plans must also contain provisions for the characteristics and communications assets that are unique to a state or local area. This is especially true for interstate areas.

Appendix I of the EAS Assessment Report contains a copy of the Memorandum of Understanding (MOU) between FEMA, FCC, NWS and the FCC's industry advisory committee. The MOU defined a framework for a cooperative effort to develop and evaluate effective Emergency Broadcast System (EBS) plans. This agreement should be updated and implemented with respect to EAS.

Finally, the government should partner with various organizations to provide funding for EAS training and education for originators and broadcasters. Emergency management and industry organizations such as NEMA, IAEM, SBE, NAB, SCTE, and State broadcasters associations are suggested. A schedule should be developed to hold workshops in each state to help the SECCs and LECCs develop and update EAS plans.

ISSUE 5:         EAS and NWR need to be integrated with the newest technologies and mass communications systems.

America is currently witnessing a proliferation of fixed and portable short messaging appliances and applications, many of which can or could be programmed to respond to standard codes. Also, since EAS was adopted in 1994, Internet use has skyrocketed. Almost everyone has a cell phone. Satellite delivered television and radio are gaining market share. Digital television and digital radio are here. All of these technologies can voluntarily participate in EAS, but none presently do participate.

Recommendation 5:

 A common terminology and communications structure are both needed to make it technically and operationally possible to link these new technologies and digital systems to EAS and NWR. A worthwhile goal is for everyone to work together in a public private partnership towards a full range of national standards, protocols and priorities related to public warning systems. The future vision is that people at immediate risk from natural or manmade disasters will obtain timely and accurate information about what is highly likely to happen or is happening via a wide variety of dissemination systems so that they can respond in ways that reduce their losses. We believe that private industry will develop most dissemination systems as successful business ventures and that warning receivers will be included in many different types of consumer electronics devices that self-activate in times of crisis.

The legacy systems of EAS and NWR, because of their nation-wide deployment and standardized protocols, can serve as the initial building blocks for all-hazard all-channel alerting systems. The two systems have an established all-hazard terminology and related codes that are included as key elements to the all-hazard alerting protocol being developed. If this recommendation is followed, it will help address the enormous challenge of integrating EAS, NWR and other systems with thousands of local emergency management agencies.

Vendors of local public warning systems need to interface with one another and the EAS equipment at broadcast stations and cable systems and NWR. Some vendors currently interface with local paging companies, email systems, and other communications channels, so why not EAS and NWR as well? One place to begin this effort is when communities develop or refine their local warning plans.

ISSUE 6:         EAS needs more public exposure. Some of the public still think EBS is in place.

EAS has less rigid public testing requirements than the old EBS. EBS weekly tests contained audio messages that were required to be broadcast during the daytime hours. Even though EAS weekly tests are still required, they are not required to have an audio message, only brief digital codes, and they can be transmitted at any hour. And even though EAS monthly tests are required to have an audio message, they alternate between the daytime and overnight hours.

Recommendation 6:

The public needs to be made aware of the capabilities of EAS, what it can do and what it cannot do. Government officials need to participate in EAS tests, especially the monthly tests, by providing information to the public about when they will use the system to alert them to danger. Also, Public Service Announcements explaining EAS need to be developed and distributed to the media.

ISSUE 7:         The latest enhancements for existing EAS equipment are permitted on a voluntary basis.

In a February, 2002 Report and Order, the FCC amended the Part 11 EAS regulations to enhance the capabilities and performance of the EAS during state and local emergencies. The Report and Order permitted the enhancements on a voluntary basis unless the equipment is replaced. All existing and new models of EAS equipment manufactured after August 1, 2003, are required to have the enhancements including the new EAS Event and Location codes. Some EAS equipment manufacturers are providing the enhancements for existing EAS equipment free while others may charge up to $150. In the mean time, broadcasters and cable operators who do not upgrade their equipment will receive messages with the new codes as unrecognized EAS messages. These unrecognized messages could include Amber messages that have the new Amber event code. Although many broadcasters and cable operators are upgrading their EAS equipment, many have not.

Recommendation 7:

Some SECCs have set their own deadlines to begin using the new enhancements, and initial reports suggest that this approach is working in some areas. The FCC should require making the enhancements mandatory for all existing EAS equipment, preferably no later than February 29, 2004, two years after the adoption of its Report and Order.

ISSUE 8:         More EAS training and education is needed for industry/government personnel.

The broadcast and cable industries undergo tremendous changes in personnel as well as company reorganizations.

Recommendation 8:

Government personnel are needed to provide more support and on-site assistance to industry. They need to attend broadcast and cable industry events and conventions to provide current EAS materials and information. In the past, an excellent way to accomplish this was to staff an EBS booth and holding meetings at industry events. Since several SECC and LECC chairs attended these industry functions, the government held meetings that were used as a forum for the SECC and LECC chairs to exchange ideas about the success and failures they encountered in their volunteer EAS work. This will help reinforce the vital message to broadcasters and cable operators that warning the public about natural and man-made disasters is a high government priority.

In addition, the Emergency Management Institute in FEMA should revive the Telecommunications and Warning course that was targeted at telecommunications professionals in the emergency management field. Subjects should include EAS principles, National Warning System topology, warning methodologies, notification systems, siren systems, and general emergency management telecommunications principles.

ISSUE 9:         Efforts should be made to induce other communications industries to join in transmitting EAS/NWR warning messages.

Most broadcasters and cable operators are not anxious to have new EAS requirements imposed. Under the Part 11 EAS regulations, all broadcast stations and cable systems are required to install, operate and test EAS equipment. Most EAS equipment sells in the range of $2,000 for the basic encoder/decoder. Options such as remote control, studio visual displays, and paging add extra costs. Also, there are costs for the labor to install and insure that the equipment is operating properly, the airtime to transmit the required EAS tests, and personnel training. Cable systems incur much higher costs. They must also install the switching capability to transmit the EAS message on all channels or follow the alternative compliance methods specified in Part 11. An all-channel cable switching capability can run into the hundreds of thousands of dollars. Since the EAS equipment base has only been in existence since 1997, and there has been a lot of work getting the operational kinks out, it!   is reasonable to expect that the broadcast and cable industries would be reluctant to implement any new hardware requirements. However, the broadcast and cable industries would probably not oppose the expansion of EAS into other communications systems such as telephone, satellite and internet as long as their own industries are not required to expend more resources.

Recommendation 9:

Since these other communications systems serve vast segments of the populace at times and in places that broadcasting, cable and NWR cannot, their participation in relaying emergency warning messages would greatly enhance the warning capabilities of the nation. Absent regulation, the government should reach out to the other public communications systems to encourage and even provide incentives for them to join in providing emergency alerts to their customers. This capability can even be used as a value-added selling point by these new communications systems and technologies.

Please provide your comments directly to PPW and if possible, send a copy to me as well.

Thank you,

Clay Freinwald
Chairman, SBE-EAS Committee