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FCC Should Focus on CAP Alerts, Not Legacy, Say Industry Groups

The FCC should focus efforts to improve the emergency alert system on the internet-based common alerting protocol (CAP) system rather than the legacy daisy chain EAS, said broadcast alerting equipment manufacturers and cable groups in comments posted this week in docket 15-94. A notice of inquiry sought comments on possible improvements to the legacy system to make it more accessible and increase the amount of text in alerts.

Is a redesign of legacy EAS worth the effort? Probably not,” said Sage Alerting: “CAP provides all of the elements desired by the FCC.” Other public safety entities said improvements to emergency alerts should integrate broadcast and wireless alerts with other alerting methods, and expressed concern about integrating changes to EAS with other existing systems. “NOAA Weather Radio Receivers would likely be incapable of processing” redesigned broadcast alerts, said NOAA.

When the agency issued the NOI in December, it also issued an NPRM on requiring stations to give preference to CAP alerts over the legacy versions of the same alerts, and enacting that rule would accomplish much of the accessibility goals aimed at in the NOI, said Digital Alert Systems. Since CAP messages contain richer information than legacy ones, favoring them “provides a simple solution to meet the FCC’s objectives without the need for architectural or EAS protocol changes,” Digital Alert Systems said. The FCC “could more effectively advance emergency communications accessibility and functionality by promoting modern IP-based platforms and solutions,” said NCTA. Redesigning the legacy system could introduce new “complications or vulnerabilities,” NCTA said. “We question the fundamental premise of the NOI that making large-scale changes to the legacy EAS is a sound strategy,” said ACA Connects.

Several entities raised concerns about how changes to EAS would work with NOAA’s National Weather Radio system, the source of most weather alerts. NOAA would need to adapt the system to match the redesigned EAS, which Sages said would require “a multi-year acquisition/implementation/deployment cycle.” The NWS system currently can’t operate with CAP messages due to a technical mismatch between the two systems that causes alerts to repeat, and solving that would be more beneficial to alerting, Sage said: “NOAA is needed to make the CAP EAS system complete.” The technical, operational and economic costs would be extremely high to replace the legacy EAS system to accommodate additional text, said Digital Alert Systems.

Increasing the amount of text in an EAS message could lead to delayed alerts and increased costs for alerting entities, Sage said. The agency might be able to increase the amount of information in legacy messages through other means, such as by triggering predetermined scripts of emergency instructions, or by adding the same sort of information contained in a CAP message using data encoded in the legacy message's audio, said DAS.

NOAA and the Boulder Regional Emergency Telephone Service Authority said a look at redesigning the EAS system should be part of a comprehensive, holistic look at alerting. Currently, EAS, wireless emergency alerts and other systems can conflict with each other, especially since not all those systems can accurately geotarget, said BRETSA. The FCC “should begin the process of evolving EAS to a geo-targetable alerting system, so that it can complement and not conflict” with other systems, BRETSA said. An EAS alert launched by a locality and received in adjacent localities may conflict with alerts launched in those areas “and cause confusion and panic,” BRETSA said.