[EAS] FW: Analysis of New FCC NPRM

[Gary Timm]

I'm glad to see there is concern on this FCC NPRM, but there are some points being brought up that I don't think will hold water with the FCC, because...
 
1) What spurred this FCC NPRM is that Congress passed a law called the CVAA (see AWARE post for details).  It MANDATES that by April 9, 2013 the FCC find a way for the sight-impaired to hear audio of any non-EAS emergency information (see the NPRM for definition of "emergency information:).
 
2) So this to me means that the FCC cannot defy Congress and must impose a new rule by April 9, 2013 allowing the visually-impaired to hear these messages.
 
3) While "warning appliances" may be great future technology, it sounds like the FCC needs a solution to this issue by April 9, 2013 to meet the mandate by Congress.
 
4) Those who feel they are already doing 90% of this mandate because they already do EAS audio on all DTV channels - this is not about EAS alerts, it is about other non-EAS emergency information (again, see NPRM for definition of "emergency information", but they refer to the instance when important info is run only in a video crawl).
 
5) So now FCC wants you to generate TTS audio of non-EAS emergency crawls you air - that to me is the issue - an expense and logistical issue - so FCC is asking, is there a better way to do it that is better/easier for TV broadcasters? - acknowledging that Congress said this MUST be done by April 9, 2013.
 
6) Yes, the second audio channel is already in use as some pointed out - for things like DVS - which is a service the sight-impaired are likely already listening to, so what better place to put this emergency audio for that same population?  The issue is again expense and logistics getting that done.
 
7) I agree with those pointing out it may be difficult for the sight-impaired to negotiate their TV set's remote control and/or on-screen menu to access the secondary audio channel - so what is a better solution than the second audio channel that can be acheived by April 9, 2013?
 
If any of this is not adding up, please re-read the AWARE post:
http://www.awareforum.org/2012/11/fcc-making-emergency-info-more-accessible-to-visually-impaired/
 
The AWARE post contains a link to the NPRM itself for further details.
 
All this discussion is great - and much of it great ideas for the future - and I don't have any special inside insight, but it seems to me Congress mandated the FCC to do something and the Commission has no choice but to do it - and all that our Comments can influence is how that mandate is accomplished by April 9, 2013.  Any changes to the mandate itself must be directed to your Member of Congress.
 
That's the way I see this sitting anyway - if anyone else reads this NPRM to say anything different, feel free to chime in - I'm strictly going by what I read in the NPRM and how I interpreted it.
 
Gary Timm
WI SECC