[EAS] [sbe-eas] IPAWS OPEN failure

[Kluger, Michael]

Note:  Cross-posting this thread from SBE EAS Exchange to the EAS Forum as well, since I think it is relevant to both lists.

Thank you, Richard, for passing along the information from FEMA.  Regarding the requirements (or lack of requirements) for what (if anything) needs to be included in the FCC log under Part 11 in regard to the IPAWS outage, I wanted to offer a few thoughts.  Please note that all of the usual disclaimers apply:  I am not an attorney, the views that I am posting in this message are only my own personal thoughts and do not represent views of the station I work for or its management, etc.:

1)If an over the air signal that I am assigned to monitor for EAS purposes experiences an outage, to the best of my knowledge, Part 11 does not require me to log that outage in my EAS log.  In fact, unless it is an extended outage, there is a good chance that I will not even know that it happened, which would make a requirement to log any and all outages in my mandatory EAS monitoring sources unfairly burdensome.  What I am required to do is log receipt of RWTs and RMTs from each source that I am required to monitor, check on an ongoing basis to confirm that I have indeed received these tests, and in the event that I have missed receiving a test, investigate the problem and document in the EAS log the reason for the problem, and if applicable, what corrective action my station is taking to remedy the problem.  Logically, shouldn't the requirement be the same for a CAP monitoring source, such as IPAWS.  I should be required to log the RWT from IPAWS each week, and I should be required to investigate and provide an explanation if I fail to receive the RWT in a given week.  Beyond that, I don't see why there should be any more of a requirement to log an outage in a CAP source than there is to log an outage in an over the air source.

2)I haven't studied the requirements for a CAP compatible EAS unit to receive FCC certification, so I could be wrong here (please correct me if I am), but I would be surprised if there is any required for a CAP compatible EAS unit to either send out notification e-mail when a CAP service is lost (especially since I don't think that there is actually a requirement to have EAS units connected to an e-mail server), nor am I aware of any requirement for a CAP compatible EAS unit to generate and store a log of CAP outages.  I am lucky in that the units I use (Sage Endec) send me an e-mail every time we lose the IPAWS service and every time it is restored, but let's say that I am using a hypothetical Brand X EAS unit which neither logs CAP outages nor sends out e-mail advisories of CAP outages.  How do I know that I have lost the IPAWS feed, unless the outage happens to come at a time when I would normally receive the IPAWS RWT?  Unless the FCC does in fact require e-mail alerts and/or logging within the EAS units for any CAP outages, I don't think it would be reasonable to require stations to log CAP feed interruptions, but only to log failure to receive an RWT via CAP.

3)On August 6, IPAWS was down for somewhere around 90 minutes, and I did not see any discussion of any need for stations to log the interruption in CAP connectivity to IPAWS, nor do I believe that I had any obligation to make any such log entry under part 11.  As far as I can tell, the only difference between the 8/6 outage and this weekend's outage was the duration of the interruption.  Is there some threshold that determines how long an outage needs to last before it is logged?  As I understand it, the Sage Endec (I can't speak about other units, since I have no experience with them) waits a few minutes before sending out a message that CAP has been lost, in order to avoid flooding people with messages if a CAP server were to repeatedly lose and restore service over a very short period of time.  If anyone is going to take the position that all CAP outages must be logged, how do we log CAP outages that are short enough that they come back into service before notification of the outage is generated?

I am tossing out these thoughts in hopes that all issues involved in formulating rules about what must be logged in regard to CAP outages will be carefully considered before any rulemaking takes place.

Mike

From: sbe-eas-bounces at sbe.org [mailto:sbe-eas-bounces at sbe.org] On Behalf Of Richard Rudman

Will/Everyone:

The Broadcast Warning Working Group sent an email to the FCC people responsible for Part 11 yesterday asking what they expect to see regarding EAS log entries for CAP outages. Attaching the email I posted this email to your EAS log for last week and this week should cover things until we  get more information on what happened, but the FCC is of course the final arbiter of that.

IPAWS OPEN Outage began at: 11:21 EDT

IPAWS OPEN Outage ended: 14:47 EDT

If we get word from the FCC about the logging issue Will raised it will first be posted on the EAS Forum list server [eas.radiolists.net<http://eas.radiolists.net/>]. We will then try to get it out to other EAS client information resources like this one.

We are also awaiting FEMA's after action report they promised us.

Richard Rudman