[EAS] ETRS Reporting

[Alex Hartman]

Comments to the comments inline:

On Tue, Sep 27, 2016 at 9:09 AM, Ed Czarnecki <ed.czarnecki at monroe-electronics.com> wrote:
>This raises a number of comments:

>>> Why did they use yet another system for reporting? Quite honestly, they
>could've used the IPAWS servers as a proxy and made the manufacturers write
>into the firmware a "reporting" system.

>Comment:  because reporting is the FCC's jurisdiction and not DHS/FEMAs.
>The FCC can't "make" FEMA do anything with their servers.  Nor, frankly,
>could they make manufacturers implement additional code/software of this
>type without a formal rulemaking.  By the way, remember that it was by and
>large the broadcast community that raised concerns of privacy and
>information gathering when CAP was first proposed.  As a result, IPAWS
>developed a more "passive" architecture that does little information
>gathering.  A related consideration is the Federal rules governing
>collection and storage of information (particularly private sector
>information), something FEMA was not organized to manage at the time.

But we're using the FEMA system to test, which was the FCCs mandate, was it not? I see a very gray line here... I think the privacy concerns, by and large, have been tossed out the window with yesterdays news. With the amount of reporting and oversight on this that's being required, privacy isn't even on the table anymore. Thus why i suggested that the IPAWS server be a proxy, redirect the responses to the FCC servers, nothing more. What's the difference if i log into ETRS and give information versus the EAS units themselves. If properly configured, both should be providing the same information, especially since there's a "paste your receipt here" question on form 2. Again, as the manufacturer, they could've easily done an NPRM for automatic reporting and yet another field in the configuration of "where do you want to send NPT/EAN data" pointing to the FCC servers.

 
>>>> Instead of relying on the 13,000 stations to know what they're doing (or
>have the staff to do it).
>However, this is exactly what the FCC (not FEMA) is responsible for doing -
>collecting information from EAS participants.

See above...

 

>>> the 3 days of productivity lost doing the reporting by hand is the
>kicker.
>I completely sympathize.  At this point, ETRS and test support is occupying
>two full time equivalents in our factory, plus my time.

I can only imagine. The only thing that kills productivity faster than facebook and cat videos is government.
 

>>> I think that the whole system needs to hire an IT design consultant who
>knows how to do mass data ingest and redesign the whole thing if what
>they're really after is "complete and utter control".
>I'm not sure what they want is "complete and utter control."  They just want
>to know it works, and that EAS Participants are ... well, participating.
>Batch filing, for instance, is a bit of a touchy subject.  We were hoping
>for true batch filing of test results - however the batch filing process is
>still basically spreadsheets requiring manual intervention anyway.   Also,
>many of the reporting questions in Form 3 are observational or require
>interpretation/investigation/explanation.  Not the kind of responses that
>could be automatically generated.  I think that is one additional area of
>improvement for the ETRS system.

By having the NPT/EAN codes, that's exactly what they want. Complete and utter control over the system. Tests ensure that they do have that control. Batch filing i gave up on, i did individuals for all of mine (for various reasons). I have a feeling that the test results will be like the 2011 test, and not show up for a year... Again, productivity issues.

Leaving the whole thing up to manual entry is entirely interpretive and left up to liars just as much. Computers don't lie. They do as their told. Thus why the computers themselves should be doing the reporting. It really is no different anymore than me hand-reviewing the logs and putting them in my files for an inspector to ask for. It's just a different filing cabinet at this point. And with online public files as well, may as well go whole hog. In for a penny, in for a pound. (Slippery slope, the whole point of moving everything online and reducing the field enforcement headcount is pretty easy to see. Taddle on yourself, just write the check out to "FCC".)

--
Alex Hartman