[EAS] Time to make the LP daisy chain an option

[Sean Donelan]

On Sat, 31 Aug 2019, Richard Rudman wrote:
> Relatively Easy Part:
>
> FCC NPRM and Rulemaking changing Part 11 so State Committees, with 
> input from their LECC's, can opt to do away with the LP daisy chain.

Not needed, because the rules don't mandate a specific state technological 
implementation.

11.55(c)(3) Participating National (PN) sources monitor LPs *** OR OTHER
SOURCES *** as set forth in the State EAS Plan. (emphasis added)

> Hard Part:
>
> Provide funding so Operational Area emergency management agencies can 
> use VHF and UHF to get EAS events to all EAS Participants to supplement 
> their current ability built in to IPAWS to get CAP EAS events to all 
> their EAS Participants without using LP's.  Funds are for repeaters and 
> VHF and UHF receivers. Frequency allocation for such repeaters should 
> not be an issue in most cases. Any current low use public safety 
> channel can have an EAS interrupt just like broadcasters do in our 
> broadcast chains.

That is a state and local funding matter.  A few states pay for a state 
relay network (satellite, microwave, etc), and stations can monitor the 
state relay network or local agency public safety frequency directly.

The FCC objects to using a telephone carrier, wireline provider or 
Internet provider as the state relay network. The FCC usually rejects an 
EAS plan because it creates a single point of failure in the alert 
distribution (i.e. two telephone circuits is still a single point of 
failure). A state relay network could be one of the two required 
monitoring sources, but you still need a second diverse, monitoring 
source.

In the olden days, there may have been some local agencies worried a 
Presidential message would block a state agency's radio network frequency 
for long periods of time. But modern trunk and multiplexed systems work 
around that.

Yes, I'm aware that some local EAS areas have LP-1 and LP-2 stations 
co-owned and operated by a single entity, on the same tower.

How do you maintain diversity, survivability and affordability?  It sounds 
like the beginning of a joke, but no one likes the punch line.

> Why Bother?
>
> Will this Part 11 change eliminate the need for all LP relays? Of 
> course not. But the "one size fits all" LP model has not served many of 
> us well. As long as we need to continue Legacy EAS, this will improve 
> Legacy reliability/penetration for when the Internet inevitable becomes 
> unreliable during major emergencies.

The belief that LP model is mandated may be a faulty assumption 
leading to group think.

Of course, it would be great if FCC and FEMA put their unwritten 
requirements in writing and published them.