[EAS] 'improving' EAS

[Sean Donelan]

On Mon, 16 Jul 2018, Gary Timm wrote:
> Regarding Live Code Testing...
> The main reason our State EMA made for Live Code TOR testing is for 
> families and schools and businesses to test their NOAA Weather Radio 
> (NWR).  The only way to trigger these legacy radios is with a real code. 
> The point was made, does our SECC want to be responsible for a death due 
> to an improperly programmed NWR when it could have been detected through 
> a Live Code Test?

Public excercises, i.e. live-code tests, should be for the public.

The purpose of the annual severe weather drill is *NOT* training for the 
weather warning meteorologist at the national weather service, and is not 
testing the NWS's own warning equipment. NWS has training facilities 
for its meteorologists and can test its own equipment without annoying 
the public using live-codes.

I don't have a problem with annual severe weather drills coordinated 
state-wide by the national weather service. The primary purpose for the 
annual severe weather drills usually given is schools and schoolchildren 
participation. School children are part of the public.

The annual severe weather drills may also be useful to the 5% (or less) of 
the public with weather radios. I don't even have a strong opinion 
whether once a year it uses the Required Monthly Test or a geographic 
likely event like Tornado (TOR) in the midwest or Tsunami (TSW) on the 
pacific coast.

My greater concern is live-code testing by potentially 30,000 to 50,000 
localities. I know, only about 1,200 agencies have signed up with IPAWS 
to date. Live-code tests should be for the benefit of the public, not 
training state and local warning officials. There are different, better, 
ways to conduct training without annoying the public.

Eliminating the waiver requirement only saves the FCC some work (150 
waiver requests since 2009, about 1 a month). It doesn't save state/local 
officials any work because the new rule still requires them to do 
everything required in past waivers. The FCC just avoids going on the 
record pre-approving a particular waiver.

Even under the old waiver process, based on Google searches in the last 5 
years it appears about 100 live-code tests by various agencies were 
conducted without obtaining waivers. In some of those cases, using a 
live-code seemed to be a regular monthly or quarterly drill on military 
bases and a local agency.

The IPAWS office likely has better records, but FEMA has not responded to 
my FOIA request yet.