[EAS] FCC NPRM on improving EAS just issued

[Clay Freinwald]

Tim - 

 

Allow my an opportunity to respond to some of your post- 

 

TS - The daisy-chain system is one of the unique strengths of EAS. Killing
it off would be about the worst thing the FCC can do.

 

CF - Some questions - 

 

1-  How do you feel that a relay chain where a single broadcast station (a
link in the chain) can fail is a good system.  Seems to me that any system
whereby  a SPOF can occur is not a good system, regardless of the mission.
The problem is there is no redundancy and without redundancy you have a poor
design.

 

2- In addition to the redundancy issue - Any LP Station can decide they
don't wish to play EAS any more - A change of ownership, management, program
director, format etc can be cause for the change.   The station has ZERO
obligation to tell anyone of that change.   WHAM Link #1 of the chain is
gone....

 

3- Why not have the sources of messages provide the distribution system??
Why do broadcast stations have to provide a message distribution system for
Government entities?

 

4- Explain why Washington State gets along just fine without the Daisy
Chain?

 

TS - Imagine a disaster that takes out the internet, or at least major
portions of it.

 

CF - perhaps you are confusing or perhaps trying to compare the Analog
message distribution of EAS Distribution with the Digital Distribution side.
The Internet is used to distribute FEMA IPAWS (As well as State Operated CAP
distribution system like Washington State, and other used - Alert Sense,
EM-Net etc)    At this time FEMA-IPAWS, or other Internet based systems will
not distribute LIVE Voice Messages - However they can and do distribute
delayed voice messages.   As an example - In Washington State

 

TS - because at least some individual broadcasters will be able to stay on
the air and get a signal out.

 

CF - I believe that a Point-Multi-Point distribution system is superior than
one that could have a SPOF issue at the start of the chain.  Example is NWS,
or the Relay Networks that we use here that are based on that topology.

 

TS - Old technology isn't necessarily bad. IMHO

 

CF- Here we ARE in agreement.  If you were to look at the Washington State
EAS Plan you would see that we continue to use both the legacy - analog-
systems as well as the new Digital CAP Based systems.    For example - If
the State of Washington issues a state-wide EAS message it does so using
BOTH systems - 1) Our Alert Sense based CAP distribution system (which is
completely separate from FEMA-IPAS and 2) our Legacy, SAME based Analog
(SRN) State Relay Network 

That consists of a Microwave Backbone feeding a state wide network of
mountain top VHF FM Transmitters.   This is true redundancy.

 

TS - Emergency systems need to be simple and foolproof.

 

CF - We are in agreement - Add Redundancy to your criteria.

 

FINALLY - 

 

I would hope that you would go beyond just posting critical comments and
make a filing with the FCC that does not just try and shoot down all that
they have proposed but will detail exactly what you feel should be done to
strengthen the EAS so it will become the type of public warning system that
you too would be proud of.

 

I would hope that the State of Washington, SECC will file comments
....Perhaps your State SECC will do the same?

 

Regards, 

 

Clay Freinwald