[EAS] BLU Alert Comments.

[Ed Czarnecki]

On Wed, 2 Aug 2017, Sean Donelan wrote:
>The threshold for sharing warnings through internal DOJ law-enforcement to
law-enforcement systems should be lower.  The threshold for using FCC public
> alerting and warning systems should be higher.

I tend to agree with this.  Higher thresholds can and should be established
within the state Blue Alert plan.  However, we already have two major
jurisdictions (NYC and Boulder CO) stating that they are already willing to
disregard even the basic thresholds in the Blue Alert legislation and the
FCC NPRM.

Does this mean that some national authority establish stricter threshold
guidelines for use in Blue Alert plans?  FCC could, but their rules would be
only apply to EAS participants, not the originators.  FEMA? probably not
(this isn't their wheelhouse).  DOJ? Nope, I don't see them putting any
restrictions on this.

There's always the position stated by the State of Washington, in their EAS
and Blue Alert plan (as summarized by Clay in his RadioWorld interview) -
blue alerts simply do not go out over EAS.
http://www.radioworld.com/news-and-business/0002/freinwald-blue-alerts-offer
-no-tangible-improvements/340122

Again, if we are really talking about two alerts a year, this may be a
tempest in a teapot.  But this could be a bit more expensive and time
consuming than the FCC posits in its NPRM.  Per our comments, the FCC should
simple re-designate and reserve LEW for the purposes of Blue Alerts.