[EAS] Manual Relay and Immediacy

[Ed Czarnecki]

One additional aspect, Sean, is the old problem of "rules", "specifications", "interpretation", and "interoperability".
The rules are a matter of administrative law, but do not rise to the level of a firm specification in a number of key areas.  So "immediate" may represent something evident to a policy maker, but has clearly run into a variety of different interpretations from engineers, developers, and systems integrators. 
Of course, firm specifications are often  easier said than done  -  just last week I spent 2 1/2 hours in a standards working group going over just one part of one sentence, out at of a 400+ page draft standard.

Edward Czarnecki, PhD
Senior Director - Strategy  & Global Government Affairs
MONROE ELECTRONICS
585-765-2254 ext. 122 | fax 585-765-9330
Reston VA | Lyndonville NY
www.digitalalertsystems.com

From: Sean Donelan
donelan.com>
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donelan.com>

On Sat, 20 Aug 2016, Al Kenyon wrote:

> 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.

In various congressional testimony and previous statements, the FCC has
said its role as the regulatory partner, with FEMA and NOAA, in the
Emergency Broadcast System and now the Emergency Alert System is
maintaining and enforcing its rules. But, the FCC said it does not
determine the requirements for EBS/EAS. The requirements came from the
(1) White House, (2) FEMA (and FEMA's predecessor agencies), (3) NOAA and
(4)industry. That may partially the FCC just telling Congress, don't
blame us; but the historical record does backup the FCC's claim.  The
FCC's Part 11 rules are supposed to reflect the requirements determined
by others.

However the FCC's Oracle of Delphi approach causes confusion, even among
the lead agency partners.

1. While everyone is trying to make the system work as well as possible,
a small part of the debate on
"immediacy" is some participants saying
they spent a lot of money interpreting the rules one way, and upset that
other participants aren't also spending money to do it the same way. And
vice-versa. Although it may not be valid justification, a lot of lobbying
in Washington DC happens because of money. Nobody cares about the rules,
until it affects their pocketbook.

2. What is the "intent" of a National Periodic Test (NPT)? Should a NPT
test the entire system, end-to-end, exactly the same as an Emergency
Action Notification (EAN), including "immediate" activation, "pre-emption"
of lower priority messages, "live" and "unlimited" transmission length,
etc. Or is the intent of a NPT to test a subset of EAN's properties in
the real-world, and other properties can be tested in a lab.

In the Sixth R&O, the FCC said the "intent" was the latter.  But the FCC
wasn't as careful editing the rules about what subset of EAN properties

the NPT must emulate.

  Pre-emption  No
  Unlimited length 2-minute maximum
  Live transmission Omitted
  Maximum hold-off Immediate

Other test codes have different rules than the system they are testing.
For example, RMT has a maximum 60 minute delay, while actual event codes
have a maximum 15 minute delay. For an RMT, does the 60 minute maximum
delay mean from the beginning of the first EAS header code, or 60 minutes
from the end of the last EOM? Does the 2-minute audio limit include or
exclude the time used by EAS AFSK and 8-second Attention Signal?

As an engineer, I understand no amount of lab testing will ever replicate
what happens in the real world. A simple broadcast chain at traditional
radio station versus a multi-state, multi-hundred channel video provider
versus a cellular mobile network are very different.

IPAWS doesn't currently support "live" streaming of messages. IPAWS
distributes a recorded
audio file, at high-speed. For a 2 minute NPT, the
difference may not matter.  For a 30 minute EAN, the difference between a
"live" stream and a recorded audio file may make a difference.

Using the EAS analog protocol, there has always been a difference between
manufactures.  Some manufacturers support "live" immediate relay for all
event codes, with a small amount of buffering, via the EAS analog
protocol. An immediate relay option wasn't limited to EAN/NPT, but was
also available for TOR and other event codes. While other manufacturers,
especially those focused on cable systems using SCTE-18, would record the
entire EAS analog message and forward an audio file to set-top boxes for
playout. EAN was handled differently, requiring force-tuning set-top
boxes for "live" transmission. Is the intent of the NPT to test the
force-tuning function of cable systems like an EAN, or can that be tested
in a lab?

Which leads to more
questions about buffering the beginning of an EAN/NPT
message during the force-tuning delay. Does the manufacturer "immediately"
transmit the "live" message, or buffer it during the switching delay as
set-top boxes tune to a different channel. Unidirectional set-top boxes
don't send a signal when they are ready. Complying with an "immediate"
rule seems less important than a (small) delay so the public can hear the
entire emergency message.

But that's why there is testing. And why I would be suprised by any FCC
enforcement action for a good faith attempt to comply with reasonable
interpretations of the rules.

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