[EAS] FCC reply comments to FCC FNRPM - interesting reading

[ed.czarnecki at monroe-electronics.com]

FEMA IPAWS' reply comments to the FCC FNRPM were posted late this afternoon, and are very much worth reviewing:

II.  Reply comments

The FEMA Integrated Public Alert and Warning (IPAWS) Division offers the following reply comments in response to comments filed by several respondents including Donald Walker, the Broadcast Warning Working Group and others regarding a readiness of supporting systems, possible extension of the currently established date for EAS participants to be capable of
receiving CAP messages and system test methodologies.

- FEMA expects to have IPAWS Open Platform for Emergency Networks (OPEN) version 3.0 in operation in a production environment and available to serve CAP messages to EAS participants prior to the end of September.

- FEMA and the National Weather Service do not expect that the majority of weather alerts will be processed through and available via IPAWS OPEN until mid to late November.

- FEMA suggests that there be an allowance for a Period of Configuration of CAP-EAS device to commence on the established date for EAS participants to be able to receive CAP messages and extend for a period of 120 days.

* During the first 90 days of the proposed Period of Configuration FEMA proposes to generate, process and serve four (4) CAP messages per day per US time zone.
* These four CAP messages would consist of a Required Weekly Test (RWT) message directed to all states within each time zone issued at 10:00 AM, 11:00
AM, 12:00 Noon, and 1:00 PM local time within each time zone.
* When an EAS participant receives an RWT message the message is normally
treated as a log-only event therefore CAP transmission of messages using the RWT code should not interrupt EAS participant?s programming and the public
will not be affected.
* These log-only RWT messages will serve as non-disruptive internal test messages to exercise the message delivery capabilities of the IPAWS OPEN CAP EAS and provide EAS participants with the opportunity to configure their CAP EAS devices and CAP message connections.
* All actual alerts received by IPAWS OPEN during the configuration period will be processed and immediately made available to EAS participants for distribution to the public.

Edward Czarnecki, Ph.D.
Senior Director - Strategy, Development and Regulatory Affairs
Monroe Electronics, Inc. / Digital Alert Systems
ed.czarnecki at monroe-electronics.com

www.monroe-electronics.com
www.digitalalertsystems.com

-----Original Message-----
From: Richard_Rudman [mailto:rar01 at mac.com]

There have been four other informal comments filed with the FCC and viewable on the Electronic Comment Filing System (ECFS) as of today:One Ministries, Inc. objected to having to buy a CAP system by the original March 29, 2011 deadline with no CAP feed to monitor until, as they phrase it, "...until September, 2011." They believe "that the FCC should only require broadcasters to purchase CAP equipment within one year of the federal government implementing its infrastructure," They also suggest that since satellite NCE stations do not have internet connectivity, NCE stations only should be required to have CAP connectivity at their main station.Ralph Brancato is asking that the FCC "RE-INSTATE and do not eliminate the Emergency Action Termination "(EAT)" message from the proposed rules." He says the EAT is needed "as a failsafe and "reset" to protect the integrity, operation and public confidence in the system." He also states that "The Public Internet connection to the IPAWS CAP server should be "PULL" from clients, not "PUSH". Public safety and timeliness of alerts can be assured as clients can connect outbound on local firewalls." Finally, he believes that "An IPAWS emergency backbone should be enabled to assure delivery at times when a denial-ofservice ("DOS") attack is made on the IPAWS server/switch."Fred Sperry said "that the header-derived TV EAS crawl would still be the standard even after the implementation of CAP. I don't believe that viewers would be confused if one station runs the header-derived crawl but another runs the more complete CAP-derived crawl." He goes on to say -- "The more descriptive crawl is an advantage of CAP that should be implemented as soon as a station is able to do so. Requiring stations to run the header-derived crawl prior to a CAP-derived crawl is likely what will cause viewer confusion."Expect longer and more detailed filings to appear on the filing deadline date. It is a common practice to not file detailed formally written Comments on until the closing date.Regards.Richard Rudman/BWWG_______________________________________________This is the EAS Forum Discussion ListPlease invite your friends to join our Forum!http://lists.radiolists.net/mailman/listinfo/easAnd, remember the main page: http://eas.radiolists.net