Excerpt From the BWWG’s Part 11 Comments: Do Not Filter CAP Through a SAME Strainer

January 20, 2012

Due to the current discussion thread on the EAS Forum about so-called CAP Converters, we thought we should post in full  our Comments on this issue:

The BWWG believes that preserving legacy EAS SAME capability has to be a very short-term solution. EAS stakeholders and the general public are being told that the CAP will greatly improve public warnings. Unfortunately, the vast majority of the public and EAS stakeholders will not know that the EAS public warning process has been improved for some time as long as CAP messages are “strained” through the SAME filter.

CAP EAS messages are already being generated by warning centers in some parts of the country and transmitted to Radio, TV and Cable systems. When heard or viewed on the air, they will sound and look no different than they did before if they default to the actions burned into the PROMs in classic EAS devices or CAP converters, or “dumbed down” by legacy capabilities built in to new broadcast and cable entry point CAP decoders. While the EAS community and the public wait for what is being called “next generation” EAS, we run the risk of the effort being labeled as the warning equivalent to building a bridge to nowhere.

When a CAP message is filtered by conversion to SAME it is analogous a CAP message being run through a filter, in short, what starts out as a rich and nourishing full course dinner winds up as a strained, thin, and watery broth. The BWWG believes that every effort should be made to integrate the capabilities of CAP into all aspects of the EAS as soon as possible to eliminate the bottleneck that SAME creates.

For example – TV Stations should be encouraged to, as early as possible, derive their ‘EAS Crawl’ from the textual information contained in the CAP message. Radio EAS should use text-to-speech converters that can automatically convey vital CAP details aurally[1] that will better assist people at risk take proper protective actions.[2]

Taking these steps as soon as possible must be done to avoid prolonging the present confusion caused by the legacy ‘Header Codes’ in the SAME message that often conflict with the voice message thereby creating misleading and erroneous messages being transmitted to the public as pointed out in Society of Broadcast Engineers Comments filed in the past on Docket 04-296.

Let us also remember that the CAP has been heavily promoted to stakeholders as a way to address long-standing concerns of the hearing and sight-impaired communities that have been (rightly so) highly critical of legacy public warning efforts.

There are, perhaps, some parallels to be drawn for the conversion from SAME to the CAP with another ‘conversion’ we have experienced, the recent transition from analog to digital TV. This process has a number of parallels. For a period of time, stations generated program content in digital that was down-converted to SDTV for analog.

So it is with EAS where the CAP can be thought of as Digital and SAME as analog. Everyone knew that digital offered much greater capability than did analog, and, the only reason we made the transition can be traced directly to the Commission committing to a “date-certain”. The lesson learned: Recognize the need to transition and provide the leadership to make sure that it takes place.

The BWWG therefore believes that when local and/or state EAS messages are available to broadcast and cable systems in CAP as well as SAME, the new rules should clearly state the unfiltered CAP message must be conveyed to the public. Setting a “date-certain” for this will not be easy, and should be assigned as a top priority for the public/private EAS stakeholder effort that the BWWG recommends be formed. The question was how best to make the transition.

‘CAP Converters’ can be thought of in much the same way we view those devices that people purchased so they could view their local TV stations on their existing TV receivers. Just like those converters – much is lost in the process. A public a risk will not received the whole warning picture.

Many of the originators of public warning messages, emergency management entities etc, at the State and Local levels, have long not participated in the EAS due to its lack of specificity.   It is hard for emergency managers to buy into a warning system that cannot always spell out clearly what the risks are, and what actions to take. CAP significantly enhances this capability, and is being “Sold” to the emergency management community as a solid investment to improve origination of all types of warnings. Many of these new warning tools are or will be features that users will have to pay for.

So, non-broadcast technologies that the public will have to pay for may well see more and faster direct benefits from CAP than warnings over “free” radio and television. The BWWG strongly recommends that every day that legacy EAS is still in use is another day when audiences of “free” radio and television” will be at this disadvantage.

The FCC must recognize that many states and areas are not waiting for the Commission to act.  The have already recognized the value of CAP and are moving forward with their own CAP systems – now!    This is a process that has significant momentum that the FCC must consider as they attempt to craft rules that will apply to those portions of the country where there have been no movement beyond legacy SAME based EAS.

This issue directly involves the present originator of most EAS warnings. The National Weather Service has, for some time, been the principal source of EAS warnings for broadcasters via their NOAA Weather Radio (NWR). NWR has well-documented issues with their legacy narrow band VHF radio system.  Regrettably, for the foreseeable future, NWS will be using SAME for warnings on that system. However, this should not, in any way, slow down the transition to CAP for everyone else. Current NWR analog broadcasts are now monitored by radio, TV and cable systems as part of their basic Part 11 compliance. In the future, the NWS will be transmitting their information, in CAP to CAP servers that will join emergency management warning center CAP servers already in operation to realize the benefits of a 100% CAP EAS. When NWS begins supplying product to the CAP Servers, broadcasters and cable systems will then be able to disconnect their NWR SAME connections. When this happens, NWS CAP messages must not be “dumbed down” by the legacy SAME filter.

[1] The BWWG thinks this is especially important in view of the growing number of broadcast entities that operate EAS in the automatic mode.

[2] Some states have already begun to deploy their own CAP based systems that already provide Voice/Textual compatibility for TV and Cable Systems (Washington State is an example) In these cases. Emergency management entities, at the State and Local level, are already generating public warning messages in CAP format and transmitting this information, via a CAP Server, to multiple radio and TV stations and cable systems. All this is being done without the use of SAME thereby providing the public in these areas with a significant enhancement of the EAS. The source of TV crawls must transition from SAME to CAP as soon as CAP is available in an area.

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