[EAS] Fixing Part 11 is not enough

[Richard Rudman]

Quoting from Barry Mishkind:
"The FCC FNPRM reply comment period ended August 4, 2011. (FNPRM = Further Notice of Proposed Rule Making). That means we are (2/15/18) at SEVEN YEARS, SEVEN MONTHS, TWO WEEKS, AND COUNTING."

Some people believe, myself included, that the FCC, while have a horse in the race, is not the agency to oversee how the race course is built or who gets to fire the starting gun. The overall responsibility to overhaul our emergency public information (EPI) and the subset of emergency public warnings lies elsewhere. Broadcasting / media are the delivery system and the long overdue national warning policy must begin with a top down overall strategy that starts with warning origination. This means recognizing that warnings are an integral component of emergency response. Some may believe that we can "fix" warnings downstream in the distribution system with a Part 11 rewrite. This is like turning on a water tap in your house, seeing nothing coming out, and trying to fix the problem on your property after finding out that all your neighbors are also without water. Going back to my equine analogy, it's locking the barn door after the horses have escaped.

Problems with any system or policy start when there is no coordinated unified strategy to drive the  planning and training for all the elements needed to execute. We see this time and time again when warning systems are tested and also when they have to be used for real. Part 11 cannot do this by itself, no matter how dire and overdue the need to rewrite it is.

We also live in an era where social media and cell phone providers are, whether we like it or not, parts of the overall warning stable. Coordination of information that flows out on Twitter and all of the other horses in the warning stable has to be done. The only place to do that is where warnings originate. That's not in any way shape or form the in the purview of the FCC.

Simply stated, timely EPI and warnings to people at risk to help save more lives and property has to be looked at as an integral part of emergency management, not just as FCC policies and practices to delivering warnings through mass media.

I submit until the United States and all of its 50 states, territories, and protectorates has a total, unified warning strategy that is set in stone in the National Incident Management System (NIMS) we will continue to spin our wheel on planning, training, testing and execution of this vital human function. Looking to the FCC, FEMA, or NOAA/NWS as individual entities cannot do it. 

Richard Rudman
Core Member, BWWG
Former Trustee, Partnership for Public Warning, Inc.