[EAS] Should the RWT EAS Code be abolished?

[Dave Turnmire]

On 11/24/2011 4:17 PM, Barry Mishkind wrote:

>...        I think I'm going to stop here. Yes, RWT's might
>        be among the simpler ways. But only if it
>        is actually used and broadcast - and checked.

I agree with this point.  In fact, in regards to testing the basic ability to get an EAS signal on the air, perhaps we should simply replace the legal requirement for an RWT with a requirement that a station's operator (or "chief operator") sign a statement in the log monthly that they have personally verified the EAS equipment had successfully put an EAS alert on the air within the last month.  How they confirmed that would be up to them... if they personally heard the RMT on their air space... fine.  If they personally heard an CAE or weather alert go out fine.  Or if not... they can reach over and push the RWT button at a convenient time in their programming and listen to it go out on the air. 

The above would eliminate RWTs that serve no testing purpose because they aren't being observed... yet still interrupt air space (if they are in fact working).  It shouldn't create undo hardships for stations that are automated and unattended most of the time (like mine)... surely whomever the designated chief operator is has dropped by the station sometime during the month!  He/she should have a copy of the RMT schedule... so they can even tune in and listen from their bedroom!

Yes, I would assume the FCC doesn't have the authority to dictate to the civil authorities involved.  But... FEMA is involved with this now so perhaps they can work something out from their end.  At the least... those of us who are involved with SECCs, etc., can exert our influence to strongly encourage the use of RWTs at all levels higher up the food chain.  And... as long as LPs are part of EAS chain... they should do RWTs... and the stations downstream should continue to be required to identify and log any discrepancies relating to reception of that RWT.

The frequency of RMTs is a tricky issue.  They are more effective for testing the system than RWTs.  But, by design, they are more intrusive.    I would hate to see a mandate from the feds to use them more than monthly.  But SECCs and LECCs should be free to decide whether in their particular environment that more are warranted.  IMHO, RMTs should be used to test from those sites that are designated in the State/Local plans as originators of alerts. 

I agree with those views that broadcasters shouldn't be tasked with originating EAS alerts... leave that to the professional emergency management community.   In our state, we have a central communications department (StateComm) that acts as a clearing house for a variety of communications... including state police, automated traffic signs, and EAS.  Law enforcement and emergency management through out the state in a variety of jurisdictions (including tribal) have ready access to them via radio, phone, etc.  If any county emergency management want to generate an EAS alert... they contact StateComm and give them the particulars and it will get distributed via our legacy analog based system as well as our CAP system within a minute or two.  If the county management aren't very familiar with EAS, the StateComm folks walk them through it.  If it involves an Amber Alert, they assure the Amber Alert guidelines are met... and it gets promptly distributed not only via EAS, but also automated traffic signs and even on displays at state lottery retailers.

I feel the above system works pretty well, and meets the needs of a rural state where the local emergency management are closest to what happens in their area... but don't necessarily have the resources (equipment, staff, training, whatever) to distribute alerts as effectively as our StateComm.  The actual EAS alerts are still targeted to the relevant counties, so the rest of the state isn't affected.  Sometimes having a little "distance" from the emergency is helpful.  An example is child abductions... emotions can run high in those situations and in a rural area, there is a pretty good chance the victim or victim's family is known to law enforcement.  The "do something... do anything" mode can lead to violations of the Amber guidelines and put the EAS system at risk.

I mention our state's method of doing this just to illustrate one way that a state can achieve the goals mentioned by some here, to get broadcasters out of the EAS origination business... while still allowing local emergency management to have access to the system.  Some states give every county direct access to a CAP server for originating alerts.  Ours hasn't gone that route... yet... but we are in the early stages of getting broadcasters, etc on board with CAP.  There are arguments against giving local counties direct access to the EAS system based upon training, politics, etc.  IMHO, at the national level, the effort should be to make sure there is an effective EAS infrastructure that works for the President... and gives the tools needed to state/local jurisdictions.  Then leave the state and local jurisdictions flexibility to implement EAS at their level in a manner that best meets the needs of their communities.

Dave