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Emergency Public Information (EPI) Issues Related to the Legal Main Studio Requirement

July 14, 2017
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PubAlertVsMainStudio

Emergency Public Information (EPI) Issues Related to the Legal Main Studio Requirement

The Original Basis for The Legal Main Studio Rule
One of the reasons given for the existence of the Legal Main Studio requirements was to have local broadcasters air timely and useful Emergency Public Information (EPI) directed to people at risk from natural and human-caused emergencies. The aim of delivering EPI to the public is to give the public protective action information to best protect their lives and property. Two examples of protective actions given in public warnings are “Evacuate Immediately” and “Shelter in Place”.

The Role of EPI
The assumption that has taken hold over time is that EPI is best delivered to the public if the originators of this information are the professionals who are in charge of managing the emergency, and the role of broadcasting and other means is to relay that authoritative EPI to the public. Using the two examples, the logic behind this becomes clear. The public must know under what conditions to evacuate immediately – where to go, what route or routes to take, what to take with them, and what to do when they get to the evacuation point. For shelter in place, the public needs to know what steps to take for the event that requires this measure. For toxic plumes, the public must be told what they need to do to seal their shelters.

Social Research on Emergency Public Information and Warnings
A great deal of serious social research have been accumulated in the years since the requirements in 47 CFR 73.1125 were published that are archived at the Center for Disaster and Risk Analysis (CDRA) at the Colorado State University. Drawing on this research, the Partnership for Public Warning, Inc. (PPW) wrote a series or reports for the FCC, FEMA, and the National Weather Service after September 11, 2001 with the goal of making suggestions for a unified alert and warning strategy for the United States. The PPW reports are archived at the Bridge Multimedia site, <http://www.bridgemultimedia.com/eas/ppw.php>.

FEMA Integrated Public Alert and Warning System
The best-known result of the PPW reports has been realized in the Federal Emergency Management Agency’s (FEMA) Integrated Public Alert and Warning System (IPAWS). IPAWS messaging is well on its way to become the standard for how local, state and national warning messages are delivered to the public. Nothing in that archived research or in the archived PPW reports sees any benefit to having non-emergency and/or law enforcement personnel acting as the source for EPI, or the major subset of EPI, emergency public warnings.

The National Weather Service (NWS)
The NWS was created to warn the public about weather-related emergencies and is fully integrated into the Emergency Alert System (EAS). NWS information works in concert with information from professional law enforcement and emergency management personnel to deliver accurate and authoritative information to the public using the EAS.

What Has Changed
As we all know, very few broadcasters still have staffs on duty to provide real time local news coverage during emergencies. With or without a legal main studio requirement the public now depends on warning and follow-on information from law enforcement, emergency management and the National Weather Service. These warning originators are gradually implementing IPAWS delivery of messages over WEA, EAS, and social media that can provide more detailed and incident-specific information to help the public do or not do what they need to protect themselves.

Conclusion
As long as station now subject to the legal main studio rules of the Commission are in full compliance with the FCC’s Emergency Alert System (EAS) rules, they will be fully capable of relaying emergency public warnings to the public if the Commission reaches the predicted decision that legal main studios are no longer needed. Current EAS rules require that each EAS Participant’s stations must be connected to local National Weather Service and local government warning originators. This is best accomplished by locating all EAS equipment at transmitter sites that are already located to reach their respective communities they are licensed for.

Richard A. Rudman
rar01@mac.com

Vice Chair, California State Emergency Communications Committee (SECC), 1990-present
Core Member, Broadcast Warning Working Group (BWWG),
Founding Trustee, Partnership For Public Warning, 2001-2003
Chair, Telecommunications Advisory Group, The Emergency Preparedness Commission for County and City of Los Angeles, 1990-2002
Chair, Los Angeles County Local Emergency Communications Committee, 1996-2002

Suggestions for EAS Improvement to the FCC – Proceeding 04-296

June 30, 2015
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Suggestions for EAS Improvement to the FCC – Proceeding 04-296

The Effective Date of the FCC’s Sixth Report and Order on the EAS comes 30 days after appearing in the Federal Register. None of the rules take effect on that date but rather have phase-in timelines of from 60 days to 12 months. The Broadcast Warning Working Group’s Gary Timm is the principal author...

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The BWWG Announces Gary Timm as Core Member

June 30, 2015
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The BWWG Announces Gary Timm as Core Member

June 26, 2015 For Immediate Release The Broadcast Warning Working Group (BWWG) takes great pleasure in announcing our newest Core Member, Gary Timm. As many Emergency Alert System (EAS) stakeholders know, Gary has been one of the most thoughtful, constructive, contributive and dedicated people working towards EAS improvement from the start. Gary has been...

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Open Letter to EAS Stakeholders: The IPAWS Modernization Act of 2015

May 5, 2015
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The EAS Stakeholder community has been waiting for more than a decade for Congress to weigh in on public warning improvement. Thanks to two U.S. Senators, we may finally see some action. Now is the time for all of us to get behind this legislation by contacting our Representatives and Senators, state and local...

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Commentary on where we must take EAS in the future

November 1, 2014
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Commentary on where we must take EAS in the future

How did we get to this place in the evolution of EAS since it was launched in January of 1997 where the means that EAS Participants use to comply with Part 11 do not all work the same way and there is still confusion about how they deal with the core last ditch national...

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June 26, 2014 – EAS NPRM Released today

June 26, 2014
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          Greetings: As mentioned earlier today on the EAS Forum remailer, the FCC today issued a new NPRM on the EAS. If you have opinions one way or the other talk about them here. If you fee strongly enough about your opinions, you should file your Comments on the FCC’s...

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Broadcast Warning Working Group Presents EAS Panel on Current Issues at NAB

April 7, 2014
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Broadcast Warning Working Group Presents EAS Panel on Current Issues at NAB

Led by Broadcast Warning Working Group core members Barry Mishkind, David Ostmo, Adrienne Abbott, Clay Freinwald, and Richard Rudman (pictures left to right), many recent EAS developments and issues were highlighted at the Las Vegas Convention Center today. The group presented the final EAS Plans subgroup report that was presented to CSRIC IV voting...

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FEMA Comment Period Open Until Dec. 2 on NIMS Changes

November 28, 2013
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FEMA Comment Period Open Until Dec. 2 on NIMS Changes

    Thanks to EAS Subject Expert Gary Timm, I found out that FEMA is accepting online Comments prior to their National Advisor Committee (NAC) meeting on December 3. Their NAC will be discussing the National Incident Management System (NIMS) at this meeting. Followers of this list know that some of the major unresolved...

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BWWG Files Brief Comments on FCC’s National Test Questions

November 4, 2013
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BWWG Files Brief Comments on FCC’s National Test Questions

  Today, November 4, 2013, the Broadcast Warning Working Group file timely brief Comments on what it feels are key issues regarding the many questions the FCC put out regarding the 2011 EAS National Test. It should be posted on the FCC’s Electronic Comments Filing System (ECFS) sometime on Tuesday, November 5, along with...

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The 2013 National Emergency Management Association (NEMA) Forum

September 12, 2013
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The 2013 National Emergency Management Association (NEMA) Forum

I recently became a member of the National Emergency Management Association (NEMA). NEMA is the professional association of and for emergency management directors from all 50 states, 8 territories, and the District of Columbia. NEMA provides national leadership and expertise in comprehensive emergency management, serves as a vital emergency management information and assistance resource,...

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