[EAS] The Real Cost of Converters

[Richard_Rudman]

Hi, Randy-

Thanks for your perspective on this. You raise some good arguments. 

I have to correct one thing you mentioned in your post. There is no federal requirement to relay AMBER EAS messages.

To respond to what you are saying, at some point the FCC, broadcasting and cable industry have to start looking at the warning function from the perspective of people at risk, and what timely warnings are supposed to -- get information to people at risk so they can take protective actions for their lives and property. 

When the Partnership for Public Warning came up with the idea for the Common Alerting Protocol (CAP), and followed through by working with other warning stakeholders to get CAP approved as an open, non-proprietary, international standard, we did so to improve the public warning process.

As some of you know, the BWWG filed Comments stating our view that use of converters will have the effect of "dumbing down" the messages available to those people at risk. Our contention still stands.

Here is what the FCC said in their Fifth R& O about what is lost by using converters:

"Because the SAME formatted message output of the universal intermediary device is functionally equivalent to a SAME formatted message delivered over the air, it theoretically should be interoperable with all or most legacy EAS decoders. However, because the output of the universal intermediary device is limited to the EAS Protocol - which is all that the legacy EAS device can process - the configuration of a universal intermediary device and legacy EAS device can only generate a SAME-compliant message; it cannot, for example, use the enhanced CAP text for generating a visual display." 

The FCC cited as their example "a visual display." Personally, I think they should not have used the visual display issue as their one example, since there are more (and in my view better) reasons to not use converters.

The benefit to people at risk listening to radios of a fully formed CAP message is that they can, if "Text-To-Speech" is used, get all the warning information in the original CAP message issued by a warning center -- a significant improvement over the canned SAME information hard coded into legacy boxes that CAP converters must be connected to. 

Now, here's where the cost/benefit argument of CAP converter devices that we are making is going to take you:

"However, because we also require that EAS Participants utilize the enhanced text in a CAP message to provide a visual display, as set forth in section 3.6 of the ECIG Implementation Guide, we will require that any intermediary devices provide such functionality by June 30, 2015, which is three years from the June 30, 2012, deadline for overall CAP compliance."

So, if you have a CAP converter, according to the exiting rules, by 6/30/15 you will have to upgrade to a fully CAP-capable device. To do this you will have to ask the manufacturer of your device if they will build you an upgrade, or buy a whole new CAP EAS box.

Question for the Group: Would it not have been simpler, easier, better and less expensive in the long run for all EAS broadcast/cable/manufacturing stakeholders for the FCC to have not allowed CAP converters in the first place?

Richard Rudman

On Mar 4, 2012, at 12:27 PM, wpio-fm wrote:

>It's a legitimate scenario but evidently wasn't enough to get into the
>mind of the Feds since they ONLY require that broadcast licensees relay
>TWO alerts: National and Amber.