At six days and counting to the first ever Nationwide EAS test, a couple of things got smaller.
To the surprise of many, the FCC and FEMA announced that what had once been billed as a three-minute (or thereabouts) test would in fact last only 30 seconds (or thereabouts). Good to know, especially for stations with crowded schedules who had already been juggling their programming line-ups in order to accommodate a three-minute alert.
No reason was given for the 83% shrinkage, although one report indicated that the change was made at the direction of Janet Napolitano, the Secretary of Homeland Security. At least some folks speculated that the government might have been concerned that a three-minute alert could have caused the 911 emergency phone system to melt down with frantic calls from a public concerned about three full minutes of EAS test.
The FCC’s official notice of the change also announced that a revised Handbook reflecting the new thirty-second test length has been posted at www.fcc.gov/nationwideeastest. It appears from the terse notice that the FCC expects one and all to print out this “updated” version of the Handbook and distribute it to all normal duty positions, etc., where such copies should be posted. Presumably any copies of the earlier edition of the special Nationwide EAS Test Handbook that was available about a week ago should be removed.
According to the Commission’s notice, more “significant developments” relative to the fast-approaching test may be in the works; the FCC encourages us all to visit its Nationwide EAS Test webpage for additional announcements of such developments. But don’t expect things there to be totally up-to-the-minute: the notice about the shortening of the test still did not appear to have been posted there nearly four hours after its release.
The length of the test itself is not the only thing that appears to have shrunk today.
This morning’s Federal Register contained a notice that the FCC is asking OMB for full three-year approval of the Commission’s electronic reporting system for the Nationwide EAS Test. As we reported last week, because of an apparent SNAFU at the Commission, the on-line reporting system didn’t get over to OMB in time for the standard three-year Paperwork Reduction Act approval process; accordingly, the FCC sought emergency approval, which OMB issued. Such emergency approvals are good for only six months, more than enough to get everybody through the November 9 test this year.
But the Commission apparently hopes to be using its on-line reporting system in the coming years – who wouldn’t? – so it had to go back to OMB. That’s what it’s done, according to this morning’s Federal Register notice, which assures the reader that the latest filing doesn’t change anything from the previous, emergency, filing: (a) “[t]here are no changes in any of the reporting and/or recordkeeping requirements” from what OMB has already aurthorized; and (b) “[t]here is no change to the Commission’s previous burden estimates.”
Hold on there. As to changes in the reporting requirements, the FCC has already revised its on-line report form in a couple of respects. Arguably minor respects, to be sure, but changes nonetheless. Wouldn’t it be a good idea to tip OMB off to those changes now, as long as you’re going back to OMB for a non-emergency review?
And about those “burden estimates”. Let’s look at the record. Back in September (according to the Federal Register), the FCC advised OMB that the “estimated time per response” for completing the on-line Nationwide EAS Test report was (and we’re not kidding here): “.034-20 hours”. According to today’s notice, that number has shrunk dramatically to a mere “.0229776 hours”.
Take a minute to wrap your mind around those numbers. According to the first estimate, the FCC was figuring that it would take a responder somewhere between 2.04 minutes and 20 hours to get the report completed and filed. That’s probably a safe range – maybe a bit extreme on both ends, but certainly most folks should be able to get the job done somewhere between two minutes and 20 hours. But according to today’s estimate, we’re all looking at a time commitment of just under 90 seconds (i.e., 1.378 minutes). Isn’t that a tad ambitious?
Of course, the more of these Paperwork Reduction Act estimates we see, the more we become convinced that they have no meaning. Take today’s notice: “.0229776 hours”? Where did that number come from? Seven digits to the right of the decimal point? C’mon. That’s particularly aggravating since anyone who has tried to complete the report should know that, even with all the coordinates and FRNs and facility ID numbers and other necessary information readily at hand, it’s probably going to take longer than 90 seconds to file a single report.
Want another example of the FCC’s dubious numbers? According to both the September notice and this morning’s, the FCC says that the “Number of Respondents” using the on-line EAS report form will be 3,569,028. Can we all agree that it’s seriously unlikely that there will be 3.5 million people, or stations, or reporting entities, filing EAS reports?
We have previously remarked on the FCC’s bizarre estimates in its Paperwork Reduction Act submissions. This latest batch does nothing to shore up our confidence in them – or in the Paperwork Reduction Act process as a whole.
