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EAS Test Failures Abound in First National Simulation, FCC Says 16 Months Later

There were failures among many types of emergency alert system participants and at many levels in the so-called daisy chain distributing EAS warnings, the FCC said sixteen months after the first nationwide simulation. There’s a “Need for Additional Rulemakings” and other steps by the commission and Federal Emergency Management Agency before another test is held, said one subsection heading of the Public Safety Bureau report. The study sought a “re-examination” of FCC state EAS plan rules, with some plans not providing enough details about alert propagation, said the report. EAS stakeholders we spoke with said they generally backed its recommendations and found it a useful document even so long after the Nov. 9, 2011, test. Members of Congress were among those who had scrutinized the results and sought such an autopsy (CD Nov 18/11 p1).

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The simulation “revealed a number of problems,” said the report (http://bit.ly/YLy0S8). Among them were “poor audio quality,” lack of a primary entry point (PEP) station to pass the alert onto other EAS participants -- which include all radio and TV stations, multichannel video programming distributors and satellite radio -- problems using alternatives to such PEPs, not getting the emergency action notification (EAN) to trigger the alert, and equipment problems. The test showed “the national EAS distribution architecture is basically sound,” because “a large majority” of EAS participants got the EAN, said the bureau. FCC and FEMA officials had said before and after the exercise that it wasn’t meant to be a pass-fail exam but a way to study the system’s use. Problems were “anticipated,” said the bureau.

Three PEP stations had “failures” that meant they couldn’t retransmit the warning to others in the daisy chain, said the report. That was a failure rate of 5 percent, it said. “FEMA has made a major commitment to increasing the number of PEPs (and by extension the effectiveness of the EAS) from the original 33 broadcast radio stations that comprised the PEP system to the 63 PEPs at the time of the test.” FEMA will increase the number to 77 by 2013, covering 90 percent of the U.S. populace, said the bureau. It said there was “a potential for consumer confusion and panic,” but education by the FCC and FEMA before the exercise was “effective,” as that didn’t happen.

Broadcasters had an EAN failure rate of 17 percent, cable operators 27 percent, said the bureau. State primary and state relay points each had a 16 percent failure rate, it said. NAB is “reviewing the report,” said a spokesman. The association is “committed to working in close collaboration with the FCC, FEMA, and other stakeholders on ensuring a reliable emergency alerting network,” he said by email. Spokesmen for the American Cable Association and NCTA declined to comment.

Problems with audio quality were apparent during the test, said the report. Our research at the time also found such issues, with an NPR satellite feed called the Squawk Channel causing one of the systemic glitches (CD Nov 14/11 p8). Because of such “poor” sound quality, in Oregon “participants were unable to broadcast a complete EAN, and anyone listening for the alert heard only the first few seconds of the test,” said the bureau. “The Commission should initiate a proceeding to consider adoption of a national code for any future EAS test as well as for an actual alert.” Equipment makers “followed inconsistent interpretations of the Commission’s rules in designing and/or programming their products,” such as Monroe Electronics having such an issue with the time-stamp associated with alerts, the report said. The company “quite literally asked the FCC what they want us to do, and we will do it,” said Ed Czarnecki, senior director-strategy and regulatory affairs. He cited a December 2011 filing (http://bit.ly/15bcM2O).

FEMA, “committed to building a modernized and fully accessible integrated public alert and warning system,” began “making significant improvements” based on initial findings of the nationwide test, said a spokesman. The agency “will continue to make enhancements to provide the best service possible to the American people,” he continued. The test “was an important step to ensure the EAS’ ability to effectively communicate critical information to the public in the event of a national emergency,” he said. “The test successfully identified the system’s strengths, as well as needed improvements to ensure timely and accurate alerts.”

The FCC should start a proceeding on “operational nationwide EAS test issues” left open after previous orders, the report said. Whether to use a Washington location code or a national one and other issues “call for a permanent, rather than ad hoc, resolution, and so should be addressed in a formal notice and comment rulemaking in which all stakeholders may have an opportunity to provide input,” it said. The report sought the restart of a Federal EAS Test Working Group to plan the next simulation, and called for an update to state EAS plans. Czarnecki and other EAS stakeholders told us they generally backed such recommendations.

The report showed there were a number of reasons why the test had problems, and the commission should move quickly to a rulemaking, said Czarnecki. “I don’t think anything should necessarily stand in their way to do a second test ... to see what other issues may remain.” Such an exercise would be “kind of a meaningless test, because it’s a test of a system that no longer is” the only way alerts are distributed, with all EAS participants now required to get warnings in common alerting protocol format, said Jim Gabbert, the California emergency communications committee chairman and a former broadcasters. Most states including his are working on being able to distribute alerts in that CAP format, he said. The working group that the report asked the executive office of the U.S. president to reconvene “should be a broader group” than the one before the 2011 test, said Gabbert. “It should be all stakeholders.” The group was comprised of the FCC, FEMA, National Oceanic and Atmospheric Administration and “other federal agencies,” said the report.

The report “teed up some pretty significant, core issues, that maybe should have been looked at prior to the test, but that might not have necessarily manifested themselves until we went through the test,” said President Suzanne Goucher of the Maine Association of Broadcasters. She’s “very encouraged” the bureau wants more attention to state emergency committees, as the order on CAP provides those committees with limited authority, Goucher said. “I don’t think the passage of time has made it any less valuable,” she said of the report. “I am in hearty agreement that the system needs to be tested nationwide,” even though the federal government’s initial plan for annual tests didn’t pan out, said Goucher. “You're testing the system on a periodic basis to find any kind of breaks in the daisy chain.” She advocated a longer test than the one held in 2011 one out of five years, with 30-second simulations in all other years.