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Concerns Raised About Delayed Messages, Time Frame in EAS Accessibility Proceeding

Alerting companies, consumer groups and industry trade groups broadly support the FCC’s proposed rule changes to make emergency alert messages more accessible but are concerned about the timeline for implementation, possible alerting delays, and how the changes might affect alerts that use the legacy EAS system rather than the internet-based common alerting protocol, said comments posted by Friday’s deadline in docket 15-94. “The deaf and hard of hearing community faces significant problems receiving complete and timely communications warning of emergencies,” said a joint filing from user groups including the Telecommunications for the Deaf and Hard of Hearing and the National Association of the Deaf.

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The FCC’s proposed changes to the text of alert messages would likely require software updates to implement, and the agency should give EAS participants sufficient time to reconfigure their systems, said numerous commenters. NCTA sought at least two years “to ensure the quality and integrity of emergency notifications distributed to their customers,” and NAB said the agency should impose a deadline “with a long enough runway” to allow equipment manufacturers to implement the changes through a regular software update. EAS equipment manufacturer Digital Alert Systems said the agency should give companies 18 months to make the changes.

An FCC proposal that would prioritize CAP messages over EAS messages sent through the legacy system was widely supported in general, but some commenters raised concerns about potential delays. CAP messages can provide more information and have higher quality text and audio, but “the risk is the added time delay when an alert is first received via legacy,” said EAS equipment manufacturer Sage Alerting. The consumer groups also don’t want messages delayed, and proposed that instead of prioritizing CAP over the legacy system, the agency should require broadcasters to run whichever form of alert they receive first but follow legacy messages with the CAP version of the same alert as it comes in. “Such measures would ensure that critical emergency information is disseminated in the most expedient manner while also pushing for the use of the more effective CAP-based alerts wherever possible,” the consumer groups said.

NAB endorsed the prioritization of CAP but said the FCC should omit radio from the requirements and ensure the legacy EAS system is preserved. Since the proceeding's goal is to make visual and audio emergency alerts match, there’s no reason to include radio, NAB said. If radio is included, it should have at least a two-year deadline to implement changes, NAB said. The FCC should “confirm and clarify that none of the proposals in the Notice will lead to reduced government commitment to legacy-based EAS alerting.” National Weather Service alerts are also currently blocked by a technical issue from being distributed to broadcasters through the Integrated Public Alert and Warning System, which generally transmits CAP alerts, said NWS. “The vast majority of EAS alerts received by broadcasters are issued by NWS,” NAB said. “That the proposed new process will not include weather-related alerts issued by NWS may frustrate” the goal of accessible alerts, NAB said. It suggested that implementation of the accessibility rule changes be delayed until NWS messages can be included.

An FCC proposal to use a scripted message for nationwide EAS tests to clarify that there’s no actual emergency could cause complications for regional tests of EAS systems that might be required to use the same script, said Digital Alert Systems, which suggested changes to the script language to make it more broadly applicable. Using a script for the nationwide test that's delivered differently from actual alerts goes against the purpose of testing the system, Sage said. “Any use of different processing or method of message construction reduces the quality of the test,” Sage said: “Improving the information in alerts in general is a laudable goal, however, tweaking the once-a-year [national periodic test] gives the appearance of an improvement, but does not actually improve the rendering of real alerts, or the other, more common, tests.”

The user groups proposed several changes to how visual alert information is displayed to make them more effective for the hearing impaired. Every message should include a web link to a page displaying complete alert message information provided through an American Sign Language interpreter and in multiple languages, the groups said. They also said the messages should remain on screen longer to allow accessibility tools to fully read them, and for the messages to flash to draw the eye of hearing-impaired viewers. “While the audio beep that is played with EAS tests and alerts has become ubiquitous and is recognized immediately by those who are capable of hearing it, a similar visual “attention grabber” hasn't been implemented, said the groups.