[EAS] Re-writing EAS

[Sean Donelan]

In practice there are no clean lines between different types of EAS 
participants.  Adding cell phone towers, university and miltary campus 
cable systems allows more geographically targeted warnings than was 
previously possible through full-powered broadcasters.  While adding 
direct broadcast satellite greatly expands the reach of national level EAS 
messages beyond the reach of most terresterial broadcasters.  It may be 
time to get both the old and new stakeholders together and try to re-write 
the entire plan.

National EAS participation:

   National EAS Particpants must have EAS equipement and carry national 
level EAS messages on all programmed channels including required testing 
with the following exceptions:

   Programmed channels which only simultaneously re-transmit programming of 
another EAS participant, by rule or voluntary agreement, including all 
national level EAS messages and required tests are not required to be 
overridden by a re-tranmission system for EAS messages.

     for example: local broadcasters (by rule), regional cable news 
channels (by voluntary agreement)

   Facilities which only simultaneously re-transmit programming of other 
EAS participants, by rule or voluntary agreement, including all national 
level EAS mssages and required tests on all programmed channels are not 
required to have EAS equipment.

     for example: FM/TV translators, cable systems with no local 
origination channels and EAS from the "head-end in the sky", community 
antenna systems

   Non-Participating National (NN) sources are EAS participants which must 
carry required tests, and sign-off during a national EAS activation. 
Re-transmission sources are not required to handle Non-Participating 
National sources differently than Participating National (PN) sources.

     for example: a cable system could exclude all broadcast stations (all 
EAS participants by rule) from cable EAS overrides without having to track 
changes of an individual broadcast station's NN/PN EAS status.

   The goal is to minimize the overhead and paperwork required, eliminating 
the need for lots of exceptions.  For national level EAS activations, an 
EAS participant shouldn't be responsible for activating EAS on a channel 
being used solely by another EAS participant.  However, it doesn't 
address the concerns of local emergency officials.

Local EAS participation:

   Authorized local officials may request local EAS participants 
voluntarily override programmed channels serving the local area for 
emergency warnings of imminent danger and testing of the warning system.

      for example: EAS should be used for imminent danger.  If there is 
time to schedule a press conference its probably not imminent danger, and 
use of EAS will disrupt normal public information communication channels.

   When a programming source's or re-tranmission system's facilities is 
operating unattended, scheduled or unscheduled, local EAS participants may 
allow authorized local officials to automatically override programmed 
channels serving the local area for emergency warnings of imminent danger 
and testing of the warning system.

      for example: a local broadcast station without a 24x7 newsroom or has 
to be abandoned during an emergency

   If a re-transmission source does not allow authorized local officials to 
override all programmed channels serving the local area for emergency 
warnings and testing, it shall not override any programmed channel which 
only simultaneously re-transmits a local EAS participant's programming in 
the same local EAS area which allows local officials to automatically 
override programming when unattended for emergency warnings of imminent 
danger and testing of the warning system.

     for example: a local cable system or FM/TV translator which no longer 
allows local overrides

   EAS participants should limit programming interruptions to the smallest 
area/audience included in the EAS message using selective alerting and 
consumer electronic equipment standards where available.

     for example: DTV/ATSC, Cell/GPS, Cable/SCTE, FM/RDBS, etc

   Again, the goal is to eliminate the need for per channel exceptions, but 
also address the concerns of local emergency officials.  It doesn't 
require cable systems support selective override or broadcasters support 
automatic local emergency messages.  But when they do, everyone gets 
something.  Finally, selective alerting should include the public's
experience and try to reduce the number of EAS interruptions the public 
feels are irrelevant to them.

Identification of override source:

   Programming sources and re-transmission sources must identify themselves 
specifically when interrupting normal programming with emergency warning 
information or intrusive tests (e.g. RWT is considered an unobtrusive 
test).

   The "EAS" originator code should not be translated as "broadcast station 
or cable system," suggest using "EAS participant" instead.

   Instead of using "We," identify the specific programming source or 
re-transmission source outside of the EAS message, for example:

    "XYZ Cable interrupts this program for the following message" audio 
followed by the EAS headers and message.
    "ABCD-TV: " followed by message crawl when overlaid over video 
programming.
    Name and/or logo displayed while force-tuned to a video details 
channel.

   Inside an EAS message, EAS participants may refer to themselves 
collectively as "we."

   The goal is to better identify who is reponsible for what is happening. 
Its only going to get more complicated as more programming is transmitted 
and re-transmitted through more technologies.  Some HD Radio and DTV 
stations are re-transmitting out of town stations already.  Some 
re-transmit the out-of-town EAS messages on some sub-channels, others 
don't.  Figuring out if an EAS alert is from the local broadcast station 
or the out-of-town broadcast station getting very challenging.