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

[Richard Rudman]

Sean is right that we do not need to make changes to Part 11 as far as how monitoring is accomplished. I did not explain my point in enough detail. 

Here goes.

I believe it would be helpful if FCC could clarify the voluntary role of the voluntary SECC's and acknowledge the voluntary role of the LECC's. Doing so without imposing a greater unfunded mandate burden on what we do would be a serious concern. If the FCC is listening to those of us in the trenches and is willing to accept input, a way to do that might be crafted. Imposing more regulatory requirements on a voluntary system without taking into account our very, very limited resources simply will not fly. It is already hard enough to find volunteers for LECC's in many markets in my state. I suspect this is true elsewhere. If the "stick-to-carrot" ratio gets worse, finding volunteers will only get more difficult.

FCC Inspectors rely on EAS plans to assess monitoring EAS Participant compliance. Successful monitoring plans depend on local knowledge of stations and local coverage influenced by interference, propagation conditions, and terrain, and sometimes local Industry politics. Especially in large states, there is no way a state committee can do its job without input from local EAS Participants. 

In Los Angeles LA County, the Sheriffs Department still originates legacy EAS on VHF. Any LA County EAS Participant can listen to that channel and comply with the LA Plan the way the plan was and is written. EAS Participants have always been encouraged to monitor LA County direct using VHF.  Some still do, some still do not.

Someone like Frank Lucia who was with the FCC in the 90's can chime in, but I think the LP idea may have come about primarily because of PEP. There are a number of ways to reinforce propagation for PEP available today without resorting to a daisy chain distribution topology, or relying on the LP model that is really another form of single point failure.

Some of the following is history many of us lived with and through, but presented here for those who were not in the business in the 90's when PEP and EAS came into being.

The experiment from the old EBS daisy chain model to LP seemed like a good idea at the time. There was and is still a need to reinforce propagation for national warnings on PEP stations. Studies after WWII on what would happen to the USA if there was no way for the government to let the public know it is up and running led to development of PEP. Google "Government Continuity"

AM was chosen as the PEP backbone delivery system based on the fact that AM broadcasting was and is still the most resilient national distribution system when everything else goes away. While the only more resilient national communications model was and is Amateur Radio, there was and is no way to use Amateur Radio as the PEP backbone. 

FM stations were not seen to be as resilient as AM stations leading to the initial small number of PEP facilities being built at AM transmitter sites. That AM practice was continued when the PEP network was built out based on realizations that PEP AM radio coverage, especially at night, is problematic.

Some of the current solutions to help reinforce legacy PEP message propagation without resorting to a daily chain with more multiple opportunities for failure: Co-located FM's with PEP stations, the NPR "Squawk" channel, satellite radio, satellite TV. Underneath it all is the realization that when power fails, the internet goes down, and cell service is impaired, short of a major national EMP event, AM radio will likely survive. 

Good reason to keep amplitude modulation and the band that supports it in our last ditch emergency public warning bag of tricks.

Richard Rudman
Vice Chair, CA SECC
Former Chair and current advisor, LA County LECC