[EAS] Manual Relay and Immediacy

[Al Kenyon]

Ladies and Gentlemen,

Okay, an earlier thread was getting pretty silly. Is there really a concern
with an NPT message causing an EAS device to hang or freeze up in a
forwarding state? There were no reported or observed cases where an NPT
message caused a program interruption greater that the nominal 53 seconds
during the seven rounds of NPT testing conducted in 46 states, 2
territories, and the District. I suspect that you need not stand there with
your hands clenched on the EAS device power cord on September 28th. In the
event of an over the air upstream failure prior to transmission of an EOM
the NPT test message retains the two minute time limit. Yeah, I know it
bites when someone else's programming runs on your station, but at least it
will be limited to 90 seconds or less (subtracting the roughly 30 seconds of
the NPT audio from 2 minutes). If it does happen, report it. There has to be
an appropriate blank somewhere on ETRS form 3 for that.

An NPT message is supposed to be aired in the same manner as your station
would relay an EAN: 

§11.54   EAS operation during a National Level emergency.

	(a) Immediately upon receipt of an EAN message, or the NPT Event
code in the case of a nationwide test of the EAS, EAS Participants must
comply with the following requirements, as applicable:

		(1) Analog and digital broadcast stations may transmit their
call letters and analog cable systems, digital cable systems and wireless
cable systems may transmit the names of the communities they serve during an
EAS activation. State and Local Area identifications must be given as
provided in State and Local Area EAS Plans.

		(2) Analog and digital broadcast stations are exempt from
complying with §§73.62 and 73.1560 of this chapter (operating power
maintenance) while operating under this part.

		(3) The time of receipt of the EAN shall be entered by
analog and digital broadcast stations in their logs (as specified in
§§73.1820 and 73.1840 of this chapter), by analog and digital cable systems
in their records (as specified in §76.1711 of this chapter), by subject
wireless cable systems in their records (as specified in §21.304 of this
chapter), and by all other EAS Participants in their records as specified in
§11.35(a).

	(b) EAS Participants originating emergency communications under this
section shall be considered to have conferred rebroadcast authority, as
required by section 325(a) of the Communications Act of 1934, 47 U.S.C.
325(a), to other EAS Participants.

	(c) During a national level EAS emergency, EAS Participants may
transmit in lieu of the EAS audio feed an audio feed of the President's
voice message from an alternative source, such as a broadcast network audio
feed.

You would think that somewhere in there they would have included language to
the effect that EAS Participants "must transmit, forward, relay or
rebroadcast the message content of the EAN or NPT event code message." Don't
fret, a version of that language appeared earlier in Part 11:

§11.52   EAS code and Attention Signal Monitoring requirements.

	(e) EAS Participants are required to interrupt normal programming
either automatically or manually when they receive an EAS message in which
the header code contains the Event codes for Emergency Action Notification
(EAN), the National Periodic Test (NPT), or the Required Monthly Test (RMT)
for their State or State/county location.

		(1) Automatic interrupt of programming is required when
facilities are unattended. Automatic operation must provide a permanent
record of the EAS message that contains at a minimum the following
information: Originator, Event, Location and valid time period of the
message.

		(2) Manual interrupt of programming and transmission of EAS
messages may be used. EAS messages with the EAN Event code, or the NPT Event
code in the case of a nationwide test of the EAS, must be transmitted
immediately; Monthly EAS test messages must be transmitted within 60
minutes. All actions must be logged and recorded as specified in §§11.35(a)
and 11.54(a)(3). Decoders must be programmed for the EAN Event header code
and the RMT and RWT Event header codes (for required monthly and weekly
tests), with the appropriate accompanying State and State/county location
codes.

So, now everyone is getting wrapped around the axle of "What does
'immediately' mean?".  I cannot, and do not speak for the Commission.
However, I can point out a few things that 'immediately' DOES NOT MEAN:

	It does NOT mean holding the message for the next break in
programming.
	It does NOT mean storing the message and flagging as the next
element played out by a broadcast automation system.
	It does NOT mean waiting for the song to end.

That much should be common sense. 

I call your attention to 11.52(e)(1), if you don't have a live operator,
your EAS forwarding for EAN and NPT needs to be an automatic function. Just
because you know when the NPT is scheduled doesn't mean you should schedule
personnel for manual operation specifically during that time window. You may
want to watch it, although it should not be very exciting, but your stations
should continue unattended or manned operation according to your normal
schedule.

I'm not going to get into the minutiae of forwarding upon confirmation of
header data  or waiting until the entire message has been received and
forwarding upon receipt of an EOM. This is the crux of the current debate
over "immediately".  I don't know that there is written guidance from the
Commission on this point unless it is buried somewhere in the text of the
6th R&O. In the case of the NPT, with its roughly 30 second audio message,
the overall difference in forwarding time will be less than a minute. One
can make valid arguments for both positions. The Commission is rightly
concerned with message delivery latency, particularly in the case of short
notice, life threating situations. We hope to learn a lot about how EAS
functions in the real world from some of the more detailed information that
will be collected in ETRS form 3.

Regards,

AL KENYON
IPAWS/EAS National Test Technical Lead
IPAWS Program Office, National Continuity Programs
Department of Homeland Security - FEMA
500 C Street, SW
Washington, DC 20472
202-212-3308 Office (new 8/2016)
202-538-4471 Cell    
Alfred.Kenyon at fema.dhs.gov