Two Steps Forward: A Simple Plan For Where We Need To Go, and How We Can Get There

February 14, 2012

The Emergency Alert System (EAS) Notice of Inquiry (NOI) proposed rule changes for EAS that included a call for “Governor Must Carry” (GMC). GMC was put into the NOI because of broadcaster complaints that governors were not using EAS to tell traffic fleeing from events like Hurricane Ike that all highways were converted to head north.  In Texas, instead of using EAS for the shuttle disaster, the governor convened a news conference where reporters asked if AMBER alerts could be used to warn people about touching pieces of the fallen shuttle. Other instances of failures to originate proper warnings are in the record. The problem is that governors do not really tell people what to do when their lives and property are threatened. That’s a job for the professionals at the National Weather Service and at local and state emergency management agencies. By the time a governor has enough information to be able to issue a personal message, harm may have already come to people at risk.[1]

During the Comment period on the FCC’s NOI, the Broadcast Warning Working Group (BWWG), the sponsor of this site, and the National Alliance of State Broadcasting Associations (NASBA) both called for a better, more rational, event-centered warning approach triggered and managed by professionals. The premise was that emergencies are event driven and time sensitive.  It makes sense to manage life safety warnings based on locally developed risk and assessments, and the need to tell the public based on those risks and threats.

On January 10 the FCC released their Fifth Report and Order on the EAS Rules. In that release they threw out the GMC provision, their attempt in the NOI to get around their inability to mandate carriage of  local operational area and state EAS events beyond the EAN code. This means broadcasters and cable system operators will not be required under the now revised FCC Rules to carry local and state EAS events except for tests, i.e., the same rules for local and state EAS as exist now. What we refer to as “local EAS” will continue as a voluntary program.

Our challenge: There will be no mandate “Stick” to force more EAS carriage. So, when CAP-enhanced EAS comes into being, can we identify a public service “Carrot” benefit for broadcasters and cable systems who are subject to Part 11 to carry life safety EAS messages, as well as a “Carrot” for the professionals who originate warnings, the local and state emergency management community[2]?

Most EAS stakeholders agree we need to encourage first responders and emergency warning centers to originate EAS CAP warnings when CAP takes effect after June, and to have as many of those who are subject to FCC Part 11 air those warnings. FEMA is helping to get this done through their IS-247 IPAWS training and certification.[3] Based on this important assist from FEMA, we think we can accomplish both goals. We can promote the “Carrot” we identified by asking local and state EAS committees comprised of local broadcasters and warning originators to designate a short, custom list of specific EAS event warnings that will encourage those subject to Part 11 to say, “we agree to carry.”

We call our proposal Two Steps Forward.

  • Step One – Agreement at the LECC/SECC level on a short list of EAS life safety weather and civil warning codes based on expert local assessment of life-threatening disasters and emergencies.
  • Step Two – Broadcasters and cable entities agree to carry those EAS warning codes

I recently made presentations to an EAS Local Emergency Communications Committee (LECC) and one of the three California emergency management mutual aid regional coordination groups to outline what Two Steps Forward could accomplish. It would first require Operational Area emergency management to become certified by FEMA (and their states) to originate IPAWS OPEN messages, and then work in partnership with broadcasters and cable systems and their local weather service offices to agree on a short list of EAS event codes that directly affect life safety. Both groups understood their respective “Carrots”, and understood that the key to doing this right is LECC and SECC partnerships built solidly around local government warning originators and those responsible for getting warnings to the public.

There is nothing in this simple proposal that will prevent stakeholders from using more codes if they want. The “we agree to carry” initiative is based on  a partnership negotiation between warning originators and the EAS entry points that convey warnings to broadcast and cable audiences.

The goal for Two Steps Forward is to send a strong, clear message that a few select life-safety EAS event codes should be aired as a life saving public service – even if airing that information is not specifically required under Part 11.

Starting small, we propose that that the Two Steps Forward short list contains just a few EAS event codes:

(1) Codes for local high risk, high probability weather life safety events based on risk assessment and

(2) the EAS EVI and SPW and CEM codes [4]

Yes, there may be arguments advanced to put in other civil codes, but the goal we have to start from is committed “agree to” buy-in by all stakeholders.

Of the three civil EAS codes, the CEM, coupled with IPAWS OPEN CAP messaging, is able to convey specific information not covered by the basic EVI and SPW EAS codes. Using CAP, originators can insert in a CEM specific life safety information such as directives to boil water, curfew details, and realistic reassurance about response measures from those in charge as the emergency response process unfolds.

Yes, emergencies are stories, and effective warnings to a public at risk are the headlines for those stories. Just like stories in print, emergency management can garner a larger audience for their role in emergency response by creating timely and carefully crafted warning headlines.

Our message to EAS originators and entry point stakeholders: Please think about doing your part to take Two Steps Forward.

[1] We believe the criticisms that resulted in the FCC proposing GMC were based on an imperfect understanding by many broadcasters, regulators, and others of where valid emergency warnings really come from.  We also believe that some in the emergency management community have up to this point never taken the value of EAS life safety warnings to heart. Our proposal addresses remedies for both of these issues.

[2] This community includes the National Weather Service, USGS, as well as State and Operational Area Emergency Management

[3] Once an authorized public safety official takes FEMA’s IS-247 course, and FEMA checks with that agency’s state, FEMA will authorize the agency to send CAP warnings through the Federal aggregator. We encourage not only public safety officials, but also all EAS stakeholders to take the IS-247 course and FEMA’s “final exam” to better understand the mechanics of IPAWS, and how it relates to the EAS [].

[4] The EAS has provisions for a number of event-specific three letter codes. EVI stands for Evacuate Immediately, SPW stands for Shelter In Place Warning, Warning and CEM stands for Civil Emergency Message

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