EAS: Very Much a Work in Progress

February 6, 2013

The National Test: What Do We Know?

FEMA originated the first-ever national EAS test over one year ago on November 9, 2011. EAS stakeholders are still waiting for action from the FCC on what the test accomplished. Most of what we know officially about test issues has come from FEMA. According to information quoted below in a FEMA post dated June 12, 2012, the test chalked up some successes:[1]

  • All Primary Entry Point stations were connected during the test and over 90 percent were able to receive and relay the EAS message.
  • The majority of EAS participants across the country were able to receive and relay the test message.
  • Active participation of the EAS community assisted in station and facility-level improvements before and after the test.
  • The EAS community took a proactive role in informing a FEMA IPAWS EAS Best Practices Guide and providing public information on the test.

• The test elevated public awareness, providing important information on EAS within the landscape of public alert and warning.

Under the category of “lessons learned”, FEMA said:

  • Outreach to the EAS community was essential to communicate expectations, develop EAS device best practices, and reinforce the purpose of testing.
  • When all technical areas of the system are properly addressed, the National EAS functions as intended and can be improved.
  • Regular and frequent testing of EAS is essential to identify mitigation strategies for a more resilient and effective system.
  • EAS improvement is a process that takes time and requires a coordinated effort of diverse participants at multiple levels with varying roles and responsibilities.

• Coordinated state and territory-wide EAS Tests in Alaska, Virgin Islands, Puerto Rico, and Nevada were essential to understand the limitations of EAS well in advance of the Test.

What We Observed About the National Test

Those of us who observed the event are well aware of other problems that marred the test. Here are several.

1. FEMA had an equipment problem that caused a nationwide feedback loop. FEMA has assured the EAS community that this problem has already been fixed.

2. A second problem was identified by Monroe Electronics, one of the EAS equipment vendors, in a filing with the FCC, Monroe said:

On December 15 Monroe Electronics filed with the FCC a statement that ignoring the “time of transmission” or “effective time” has “the very real potential of hindering the security and effectiveness of next generation alerting systems, including a possible impact on coordination between EAS, CAP EAS and CMAS/PLAN alert messaging.”

Some EAS equipment, Monroe relates, “acted on the “time of transmission” of the alert in the JJJHHHMM portion of the SAME header, treating the start time of the EAN message as 3 minutes past the actual start of the event. Other EAS equipment, they relate, “disregarded the JJJHHMM “time of transmission” of the alert”.[2]

The time problem potentially applies to all EAS events, not just national tests.

3. Another problem identified long before the national test took place is cable override. Not all cable systems have the capability to do selective override when an EAS event occurs. This means that on-air stations that may be carrying emergency protective action information after an EAS warning has been issued can be interrupted by an EAS message carried by the cable company not capable of selective override. This is a very complex issue with, according to cable industry experts, no hope of a rapid and/or cost-effective solution that will satisfy both cable operators and the EAS community.

The cable override problem just made news. A cable system in Tennessee recently overrode a local TV station carrying much-needed protective actions with an EAS activation. However, the EAS event did not have the proper End-Of-Message (EOM) code – locking the TV station up until the equipment timed out. The Tennessee Broadcasters Association, long aware of this issue, was quoted in an article in the Tennessean newspaper dated January 31, 2013:

The broadcasters association has been working for two years to convince the FCC that “forced tuning,” a cable override of local television stations, is potentially dangerous for viewers,” said Whit Adamson, the association’s president. In a letter to FCC Chairman Julius Genachowski in May, Adamson requested a “selective override” for local Nashville news stations. The letter has not yet received a response, Adamson said.”[3]

4. The next problem has to do with EAS equipment that apparently aborted the EAN when that equipment detected a second set of headers. We have to thank FEMA’s now corrected issue that caused the “echo” problem that exposed this apparent device flaw. Note: The BWWG is intentionally and carefully using the modifier “apparent” because we think that simple tests in FEMA’s own conformance lab can confirm or deny if this problem exists, and if so, to what degree. Broadcasters in the state of Nevada, with two PEP stations, have again volunteered to be the site of another “mini-National EAS test to determine if this problem has been resolved.

5. A key national EAS EAN element still needs to be tested. As we know, the EAN is the one exception to the EAS two-minute message time limit Until we have test longer than two minutes, we will not really know if the longer EAN message length for national EAS emergency warnings actually works as intended under real world conditions.

6. EAS stakeholders are still wondering about the fate of the FCC Mapbook. Will it stay or will it go?

7. Will the FCC adopt the 000000 national FIPS code, sometimes referred to as the ANSI number, or not?

What’s Next?

The Broadcast Warning Working Group hopes that the FCC acts soon to address all open EAS issues. Knowing that only one of the national test issues we outlined has been fixed as of February, 2013, to say the least, is disappointing.

Much of the equipment tested on November 9, 2011 has since been replaced with new CAP-aware gear. While the classic EAS functionality of new equipment should be the same as the classic EAS boxes for the national EAN code, that assumption has not yet been tested in the real world.

Overall testing under controlled, closed laboratory conditions beyond FEMA’s excellent IPAWS OPEN testing program is needed. We hope that the FCC can work out an arrangement with FEMA to do testing for overall EAS performance and conformance.

Planning a second national test should be an FCC priority to make sure all currently installed EAS equipment made by different manufacturers can “play nice” with each other, and to assess progress in resolving all outstanding issues. Part of the process leading to the next test should be an improved national test reporting system that will confirm for us that our reports have been filed, just like countless other online reporting sites for other FCC systems can do.

As part of the preparations for the National EAS Test, the FCC revised its EAS Handbook to reflect the realities of an EAN message. They prepared an EAS Handbook specifically for the 2011 National Test. The FCC said they would revise the EAS Handbook in conjunction with the rewrite of the Part 11 Rules. However, since the National Test, there’s been no revision to the Handbook and EAS clients are apparently back to using the faulty 2007 revised Handbook as mandated by FCC regulations. This leaves EAS clients open and vulnerable to mistakes and problems if a real National Warning is issued.

The BWWG also wishes to remind the EAS community that the FCC said in its Fifth Report and Order that it was deferring ruling on SECC rules, RWT/RMT changes, the EAS Checklist, and other issues until analysis of the National EAS Test results was completed. With no word yet to date on those outstanding items, we are led to the presumption that those decisions are on hold until the long-awaited national test report gives them some direction. This seems to put on hold approval of revised EAS plans by the FCC. If we are wrong about this, we hope the FCC will tell us.

There are other areas that FEMA can help with – the sooner the better in our opinion. As of this writing (February, 2012), the only activity that most people are seeing coming through IPAWS OPEN polling are the Monday morning weekly tests. PEP needs to be brought on board as the national IPAWS OPEN warning component. FEMA also needs to redouble its efforts to encourage certification of local and state warning centers to originate warning messages through FEMA IPAWS.

There is a lot left to do. We have only skimmed the surface of CAP capabilities that can enhance the EAS, and creating partnerships that cover the warning process from origination to reception by people at risk. Working toward a truly effective national warning strategy and system in which EAS plays a major role will pay off in helping to save more lives and property.

The BWWG invites you to air your constructive thoughts and suggestions on this article on the EAS Forum list server: http://lists.radiolists.net/mailman/listinfo/eas

[1] http://www.fema.gov/emergency-alert-system-eas#2

[2] As quoted in this EAS Forum posting: http://eas.radiolists.net/data-from-national-test-sparks-comment-to-the-fcc/#_ftn1

[3] http://www.tennessean.com/apps/pbcs.dll/article?AID=/201301310210/BUSINESS04/301310042&nclick_check=1