[EAS] BLU Alert Comments.

[Ed Czarnecki]

As Sean has noted, there would seem to be relatively few qualifying cases
under the activation criteria established in the legislation for Blue
Alerts.  However, I as noted, there are multiple jurisdictions already
pressing for expanding the scope of the program beyond law enforcement (note
- watch for the real possibility of the Hill expanding the coverage of the
Act ... there are already agencies approaching Congress about expanding the
scope to include Fire and Paramedics per NYC's comments about all uniformed
personnel).

There have been a few more filings posted.  

- NAB - seems to be supporting a new event code.  We were, of course,
disappointed to see the NAB agree with the 6-month implementation period,
which may have the effect of requiring over 80% of their television
broadcaster members to take the extra effort to apply for waivers (not sure
NAB may have fully understood that impact on their members).

- NCTA - in line with the above, NCTA reinforces need for well-defined
criteria for Blue Alerts, and also advised the FCC that it "seriously
underestimates the time it takes to deploy a new EAS code" since "Full
implementation of Blue Alerts will require operators to not only download
and install software in each of their EAS encoder/decoders but they must
also test the new software on a variety of downstream devices, operating
systems, and signaling formats and protocols in their video distribution
systems end-to-end. criteria for Blue Alerts."  This agrees with what we had
stated in our comments, that the total process from the manufacturer through
the cable participant is going to likely extend beyond 6 months.

- Motorola Solutions (dispatch, two-way radio systems) filed in favor of BLU
event code (I'll be cynical and categorize this as a company marketing
statement, to fall in line with their main public safety customer base).

- American Cable Association - link to filing is broken on ETRS, but in sum
they supported our proposed to redesignate the "LEW" code for Blue Alerts,
and also support the FCC's proposal to allow EAS Participants to implement
the new event code on a voluntary basis until they replace existing EAS
equipment.
		
- Sean Donelan - still reading through these comments.  Worth several reads.

On Weds, 3 Aug 2017, Sean Donelan wrote:

That's where this problem gets difficult.

The Blue Alert may be a special interest code, but there are mass-casualty
and fugitive incidents where civilians, public safety first responders,
other officlas are killed or serious;y injuried.  Law enforcement may not
have been the initial target of the attackers, but ancillary or secondary
victims.

2015 San Bernardino shootings
2014 Fort Hood shootings (large military bases can now use WEA)
2013 Boston marathon bombing
2013 Christopher Dorner shootings (California Blue Alert)

Even if no law enforcement or government officials had been injuried, some
type of public warning would be reasonable because the assailants showed no
sign of stopping or choice of victims. Waiting until a police officer is
injured or killed before warning the public doesn't make sense.

That's why I'm somewhat agnostic whether there is a new EAS event code or
uses and existing EAS event code.  Its not if there is a special code, but
whether officials get enough training and authority about how to warn the
public about threats to the public (law enforcement and other first
responders are also members of the public).

The original problem the National Blue Alert law was intended to solve was
the Baltimore Police Department wasn't able to quickly contact the New York
City Police Department with a warning message. Most Blue Alerts will be
treated as "Law Enforcement Sensitive" and never released to the public.

Since 2008, there has been 19 public Blue Alerts, which I found with Google.
That's about 2 per year across 28 states. Not exactly an overwhelming
number. Law enforcement public information officers are primarily trained to
control the release of information, not warn the public.

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