From 2011 nationwide test, lessons learned lead to system tweaks, electronic reporting system

Nearly four years ago the FCC (along with FEMA) conducted the first ever nationwide test of the Emergency Alert System (EAS). Now, after analyzing the performance of the EAS during that test, and after twice soliciting input from interested parties, the Commission has decided to tweak the system. This will be of interest to all EAS participants, since within the next year or so their equipment will have to accommodate the tweaks.

Header Code Tweaks. The first two changes the FCC has adopted involve EAS “header codes”. As we all know, the EAS system is a “daisy-chain” arrangement by which alerts percolate down through EAS participants and out to the public. An EAS alert – real or test – is triggered when a message is sent by an authorized person or office. The message contains a “header” consisting of certain coded components that permit EAS equipment down the daisy-chain to identify the originator of the message, the type of event in question, the geographic area affected by the alert and other useful information. It is obviously important that this coded information – particularly the “location” and “event” codes” – be interpreted correctly by EAS gear downstream so that the message will be accurately transmitted to the proper audience.

The first problem that surfaced during the 2011 nationwide was the location code, or, rather, the lack of one. Location codes allow EAS gear to determine which alerts pertain to which particular geographic area(s). There is, after all, no reason that an EAS participant in, say, Alaska should issue an alert concerning some emergency local to, say, Florida.

While the EAS designers had provided location codes for each state, they hadn’t provided any for a nationwide alert, so there was no way to indicate that the nationwide test was intended to trigger EAS receivers throughout the system. Oops. The 2011 test was sent using the location code for Washington, D.C., but that didn’t do the trick because some equipment rejected the alert as being “out of area”.

The solution: designation of six zeroes (as in “000000”) as a national location code for any future nationwide tests (or, God forbid, actual nationwide emergencies). That happens to be the national code already used in the Common Alerting Protocol (CAP), so its adoption for EAS purposes will insure consistency between EAS and CAP, which is what you’d want in the event of a real national emergency. (For more on CAP, check out our post from a couple of years ago.)

The good news: According to the Commission, the six zeroes code can be accommodated by most equipment already in use, either as is or with a mere software update. The bad news: Adoption of the six zeroes code will still likely cost some affected EAS participants more than $2 million in the aggregate, split roughly evenly between cable operators and broadcasters. Readers will be comforted to know that the FCC views that figure as “negligible” and has decided that, in any event, the benefits justify the cost. So six zeroes is the new nationwide location code.

The second header problem involved the “event code” to be used in a nationwide test. The event code tells EAS equipment what type of emergency is involved. There are several dozen possible event codes – you can find them in Section 11.31(e) of the rules – ranging from “Avalanche Watch” through “Volcano Warning” and on to “Winter Storm Watch”. While the list includes a “National Periodic Test Code” (NPT), in the 2011 test the Commission instead used the EAN – “Emergency Action Notification” – code.

EAN is the code used when there is a for real national emergency. Because such notices, if necessary, will clearly be of the highest priority, EAS equipment is programmed to move EAN messages to the head of the line, bumping any other EAS message that may otherwise be in the way. (NPT messages don’t get that priority.) And unlike NPT and other event codes – which are limited to two minutes (to permit EAS units to reset after two minutes in the absence of an “end of message” (EOM) code) – EAN messages can be any length. The 2011 test was originally scheduled to run three minutes (that was later ratcheted down). Because the organizers wanted the test to be as realistic as possible, they used EAN rather than NPT in 2011.

That resulted in problems. The EAN header, as expected, generated a visual message saying there was a national emergency, but the audio said that it was only a test. Anticipating that, the Commission and FEMA had engaged in extensive outreach prior to the test to alert the public that a test would be conducted. They had also produced an “Only a Test” slide for use televisions stations and video service providers to use. Nevertheless, confusion still occurred, particularly among members of the public with disabilities. (As it turned out, some cable providers couldn’t display the “Only a Test” slide.)

To deal with this event code problem in future tests, the FCC had three options. It could continue to use EAN – not a desirable alternative, given the problems encountered when it did just that in 2011. Or it could re-work the NPT code to act like the EAN code, with its prioritization and extra length. Or it could simply elect to use NPT in its existing form and forgo precise verisimilitude. The Commission has chosen that last option.

As it turns out, re-jiggering NPT to emulate EAN would be time-consuming and expensive – more than $3 million, according to FCC estimates. By contrast, since NPT is already included in the list of codes, all (or at least the vast majority of) EAS equipment currently in operation is set up to process NPT messages. While some EAS participants may have to reconfigure their gear so that it automatically responds to the NPT code, that apparently is a minor chore easily accomplished. In the Commission’s view, a nationwide test using NPT should adequately test the overall EAS operation.

Electronic Test Reporting. After the 2011 nationwide test, EAS Participants were required to submit test results data, either on paper or through a temporary electronic filing system. Most took the electronic option, which not surprisingly provided data much more promptly than did the paper route. Happy with those results, the Commission has opted to implement a permanent, and mandatory, Electronic Test Reporting System (or ETRS).

ETRS will involve three separate forms. The first will simply identify the EAS participant. The second will be a “day of test” form to confirm receipt of the nationwide test alert (and, where applicable, propagation of the alert downstream). And the third, to be filed within 45 days of the nationwide test, will require participants to report detailed information about their receipt and propagation of the alert, including discussion of any complications encountered along the way.

ETRS will look a lot like the 2011 electronic filing platform, but it will have more bells and whistles. Data drawn from the Commission’s databases (e.g., ULS) regarding EAS Participants will pre-populate fields on the form. EAS Participants will be able to retrieve previous filings for 30 days to correct errors, get receipts verif­­ying submission of completed reports, and file their reports in batches. Heads up on two points, though. First, as with just about every FCC form, filers will be required to attest to the truthfulness of their filings. And second, while the form will permit filers to enter their latitude and longitude in separate fields, it will require use of NAD83 figures, not NAD27.

The FCC’s Public Safety & Homeland Security Bureau (or just the Bureau for our purpose) will release a public notice providing more details as we get closer to the ETRS launch date. Once the form is officially available, EAS Participants will be required to review and update the pre-populated fields and make any necessary corrections.

Visual Crawl and Audio Accessibility. EAS alerts are supposed to be both aural and visual, with the latter generally displayed either as a page of fixed text or a video crawl at the top of the screen. The 2011 nationwide test turned up some problems on this front, particularly with respect to disabled viewers. Video crawls scrolled across some screens too quickly, the font in some visual messages was difficult to read.

Some commenters suggested that more time should be provided to allow stakeholders to resolve the accessibility issues, but the Commission was not in a waiting mood. While the FCC urged continued collaboration in the private sector, it concluded that at least some basic rules are needed now. Accordingly, the EAS rules have been amended to require that visual EAS messages be displayed in a size, color, contrast, location and speed that is readily readable and understandable. The rules don’t specify a particular font size or crawl speed, but they do require that the entire visual message be displayed at least once during any EAS alert.

The Commission also reiterated the existing requirement that visual messages be displayed at the top of the screen or where they won’t interfere with other video messages. To the requirement it added language mandating that the visual message not contain overlapping lines of EAS text or extend beyond the viewable display (except for crawls, which of course are intended to scroll on and off the screen).

As for EAS alert audio, the Commission will now require that the message be played in full at least once during any EAS alert. The Commission also said it expects audio messages to be delivered “in a manner and cadence that is sufficient for the consumer who does not have a hearing loss to readily comprehend it.”

Next Steps. Recognizing that EAS is a work in progress, the Commission has directed the Bureau to continue collaboration with FEMA and other stakeholders. That collaboration will include a workshop, hosted in conjunction with FEMA, focusing on (a) increasing the flexibility of the EAS to expand its use by emergency managers at the state and local levels, and (b) the improvement of alert accessibility. Look for the workshop to happen before mid-September.

Meanwhile, when will EAS participants be expected to comply with the new rules?

Participants will have 12 months from the effective date of the new rules to get their equipment set up both to use the six zeroes code and to respond automatically to an NPT alert. They will have six months from the effective date to insure that they comply with the visual display legibility, completeness and placement standards.

Meanwhile, the required review and update of pre-populated fields in the ETRS will have to be completed within six months of the later of (a) the effective date of the ETRS rules or (b) the official launch of ETRS. We’re betting that the latter of those two potential deadlines will be the one to worry about. That’s because the ETRS will be an “information collection”, which means that the FCC will have to get approval from the Office of Management and Budget before ETRS can be rolled out.

What is the effective date of all these new rules, you ask? Thirty days after Commission’s order is published in the Federal Register. Check back here for updates on that front.