[EAS] Initials in EAS codes don't need to match the description

[Sean Donelan]

FEMA finally submitted its official comments in the FCC NPRM/NOI.

https://ecfsapi.fcc.gov/file/10517879003894/FEMA%20Comments%20to%20FCC%20NPRM%2020210510.pdf

Its a human thing, seeing patterns where they don't exist.

There is no technical requirement for coded fields in the EAS 
protocol to match the initials of words in the description.  But humans 
want the initials in the EAS codes to be related to the words in the 
descriptive labels.

Sometimes, the english descriptive label does not match the initials 
in the EAS protocol code.  For example, WXR == National Weather Service,
doesn't seem to cause a lot of confusion, because the public almost never 
sees the WXR code.

In the early 2000s, NOAA asked FCC to changed the EAS ORG code for the 
National Weather Service from WXR (Weather Radio) to NWS.  The FCC 
declined to change the ORG code because changing the code would be 
incompatible with existing commercial and consumer radios.  The same 
reason why TOR - Tornado Warning and SVR - Severe Thunderstorm Warning 
weren't changed to follow the ??W pattern for other warning codes.

However, in the same rulemaking, the FCC did change the descriptive label 
for the ORG code "EAS" from the old descriptive label "broadcaster 
or cable system" to "EAS Participant."  The coded field "EAS" stayed the 
same, only changing the descriptive label.

The public rarely sees raw EAS codes.  Instead, most consumer and public 
facing equipment displays a label in the user's preferred language, which 
may be a language besides English.  If the concern is just the descriptive 
language label, with no change to the protocol behavior, avoid creating 
protocol incompatibilities by changing coded protocol fields.

In addition to the EAS protocl, the coded fields are copied in many 
downstream protocol standards for cable tuner boxes, siren controllers, 
etc.  Changing coded fields in protocols creates long-term incompatibility 
as consumers and other user equipment needs interoperability testing or 
life-cycle replacement.  That's why most protocol designers try to 
maintain backward and forward protocol compatibility.

If FEMA (which has changed its name and initials a few times over 
the decades) wants to change the english description for PEP (or an 
alternative, the old Emergency Action Notification Network ORG code), the 
translation doesn't need to use the initials P.E.P.  And likewise, the 
coded ORG field initials don't need to match the descriptive label, 
especially if equipment supports multiple languages.

Some manufactures already use different public labels for PEP/EAN in 
multiple languages.  The FCC has never said they couldn't.