FEMA, NWS, Broadcasters and MVPDs Push Back on FCC Multilingual EAS Proposal

The Federal Emergency Management Agency and the National Weather Service (NWS) joined commenters from the broadcast, MVPD and emergency alerting industries in pushing back on an FCC proposal (see 2402150053) requiring multilingual emergency alert system warnings facilitated by scripted templates, according to comments posted this week in docket 15-94. Though nearly every commenter acknowledged the importance of multilingual EAS, they also said the FCC’s proposal is too preliminary, would greatly burden broadcasters and MVPDs, and in some cases isn’t technically feasible. “The use of pre-installed templates may not be an effective approach,” said the FEMA Integrated Public Alert Warning System Program Office.

Templated alerts can't contain the sort of specific information that gets people to react appropriately, and the costs of providing them could drive away entities that would otherwise participate in EAS, FEMA said. “We do not envision fixed templates at any point in the near future because of the dynamic nature of NWS warnings and the need for localizations specific to events and locations,” said the NWS. FEMA also questioned the limitations of the FCC’s list of required languages. “Various languages have multiple dialects,” FEMA said. “For example, Chinese has at least 11 different speaking dialects and two types of written characters. FEMA recommends FCC conduct further research on language and dialects.”

“There will be a trade-off under the FCC’s approach between providing access to non-English alerts and the content of alerts because EAS messages will have to be stripped down to the bare essentials for pre-translation into pre-canned scripts,” said NAB. The proposal requires entities to issue multilingual alerts in only the languages they program in, so many non-English speakers will still be unable to receive alerts in their own languages, said the Multicultural Media, Telecom and Internet Council, a longtime advocate for multilingual alerts. “The effectiveness of the pre-scripted alerts is, therefore, inherently limited,” MMTC said.

While most of the posted comments thrashed the proposal, some organizations supported the FCC plan. The proposal would “promote inclusion of people with disabilities and will ensure access for people with disabilities, older adults, and individuals for whom English is a second language,” said the Wisconsin Department of Human Services Office of the Promotion of Independent Living. The FCC could create the templates using existing message structures from IPAWs and other emergency alerting entities and translated by experts into the needed languages, The International Association of Emergency Managers' U.S. Council said. A joint filing from the National Association of the Deaf and other groups representing hearing-impaired consumers praised the proposal but said it should make American Sign Language mandatory along with the other languages. The FCC “should include the third most commonly used language in the United States (behind only English and Spanish) in mandated template-based EAS alerts,” the groups said.

Many commenters said the FCC’s proposal is too preliminary, and multilingual alerts should instead be the focus of an advisory committee or a working group. The NPRM “reads more like a Notice of Inquiry (NOI) as it provides only a bare construct of the FCC’s proposal,” NAB said. “The proposals being considered here cross several industries and cross several federal, state, and local agency boundaries,” said EAS equipment manufacturer Digital Alert Systems. “The FCC should seek to coordinate with the FEMA IPAWS program office in assembling and empaneling a working group" to examine "these proposed objectives.” The NPRM “is an interesting first step, but it is not developed enough to go directly” to a report and order, said Sage Alerting. The agency should direct the Communications Security, Reliability, and Interoperability Council to study the proposal, ACA Connects and NTCA said jointly.

Large and small broadcasters and MVPDs united in calling the multilingual EAS proposal prohibitively burdensome. NCTA, Verizon, ACA Connects, NTCA and DirectTV said the proposal would require a massive overhaul of equipment for MVPDs and is essentially technically infeasible. Existing equipment lacks "the ability to force tune to an alert that matches the language of the programming the viewer is watching,” said Verizon. The proposal “would require DIRECTV -- a declining business -- to substantially reengineer its EAS system at costs that could reach hundreds of millions of dollars,” DirecTV said. Cable EAS architecture “cannot currently support” the template proposal and could be reengineered only for cable systems that use internet protocol-based set-top boxes, NCTA said. Even so, “implementing this capability would be an enormous, costly, and lengthy undertaking requiring years of standards and software development,” NCTA said.

NAB said the proposal would likely require that broadcasters purchase multiple EAS devices at considerable expense to accommodate proposed multiple alerts in multiple languages. The agency is already considering other EAS proposals that are likely to cost broadcasters, said NAB, citing a new EAS code for missing adults and mandatory broadcaster participation in the disaster information reporting system. “An additional requirement here or there, along with the slew of other regulatory mandates aimed (often only) at broadcasters, collectively take a great toll.”

The proposal “is a part of Chairwoman Jessica Rosenworcel’s aggressive agenda that mistakenly assumes that all broadcast stations are owned by large corporate conglomerates,” and “provides absolutely no consideration to the many broadcast stations, especially in radio, that are owned and operated by groups that represent minorities and other oppressed groups,” said low-power FM entity REC Networks and Riverton Radio Project in a joint filing. Noncommercial radio stations have extremely limited budgets and should be excepted from a multilingual alerting requirement, NPR said. Both NPR and NAB said that one way to lessen possible burdens from the proposal would be for the FCC to take up a pending proposal to allow broadcasters to satisfy EAS requirements with software rather than physical equipment (see 2306020064).

MMTC said the FCC should augment multilingual templates with the “designated hitter” solution long advocated by MMTC (see 2203100067). Under such a plan, English-language stations in a market use their broadcast to host foreign-language emergency information translated by local foreign-language stations. MMTC also said the FCC should consider requiring live operators to provide emergency information for non-English speaking communities “within the fast-evolving local circumstances of an emergency.” Prescripted alerts “are an important tool in meeting the needs of a multilingual population but cannot account for the inherent unpredictability of emergencies,” MMTC said.