[EAS] FEMA/Ad Council PSA issue

[Rich Parker]

Thanks for this Al - but it is still a bit confusing - I tend to agree with Mike that if the desire is to familiarize the public, then perhaps the FCC needs to make a declaratory ruling to amend 11.45? 

But then one could also make the equally valid argument that the weekly/monthly tests are supposed to perform that very function of public familiarization, right?

It's particularly awkward since 11.45 clearly says  (as we all know) "No person may transmit or cause to transmit the EAS codes or Attention Signal, or a recording or simulation thereof, in any circumstance...." - the key words here being 'any circumstance'.   
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It seems like any 'difference' contained in section 10.520 is so insignificant as to be meaningless - unless it all hangs on the 'timing' differences. 

- where 11.31(2) says "The Attention Signal must be made up of the fundamental frequencies of 853 and 960 Hz. The two tones must be transmitted simultaneously." 

vs (as you've noted) 10.520 says (a) The audio attention signal must have a temporal pattern of one long tone of two (2) seconds, followed by two short tones of one (1) second each, with a half (0.5) second interval between each tone. The entire sequence must be repeated twice with a half (0.5) second interval between each repetition

(b) For devices that have polyphonic capabilities, the audio attention signal must consist of the fundamental frequencies of 853 Hz and 960 Hz transmitted simultaneously.

(c) For devices with only a monophonic capability, the audio attention signal must be 960 Hz.

So the tones are exactly the same - (albeit the timing differences) - but even in that section it still says:

(d) The audio attention signal must be restricted to use for Alert Messages under part 10.
                                       ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
which a PSA is most assuredly not, thus even that argument in favor of allowing it tends to fall apart - again, unless it all hangs on the 'timing' difference - which is a pretty squeaky loop-hole to squeeze it through.....

And to me it still sounds like that contained in that very section (d) itself is 'defacto' the same restriction laid out in 11.45, and whatever 'argument' there was in favor of allowing that was incorrect, yes?

If they (FCC) want to change it, then fine - but FEMA should try to understand that we all need to work from the same rule book ;)

Rich Parker
Vermont Public Radio
Vermont SECC  

----- Original Message -----
From: "Alfred Kenyon" <Alfred.Kenyon at fema.dhs.gov>

The intent of the FEMA WEA PSA is to familiarize the public with the alert signal associated with Wireless Emergency Alerts (WEA). The audio in the PSA conforms to the specification for the Wireless Emergency Alert common audio attention signal as described in CFR 47 Part §10.520:

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