[EAS] Draft response to FEMA's recommended changes to EAS (FCC 21-77)

[Sean Donelan]

True. But ...

FIPS (I know FIPS is the obsolete term) is from the FORTRAN/COBAL era of 
standards, which used the standard that "0" == "ALL" value instead of "9".
The "9" was often used as a placeholder in COBAL PIC format fields, so it 
was avoided as a value.

See punch cards.

For example, the CCC = "000" in the county means "entire state." And the P 
= "0" means entire county. And "000000" means the entire U.S.

On the other hand, the P code "9" means "Southeast".  And NOAA/NWS already 
uses "999000" codes as its testing value. And other values like "98" have 
been used by NWS marine areas.

Like other decisions, it was arbitrary; but "00" and other alternatives 
are already taken.  And "99" seems to fit best with how the census bureau 
used FIPS coding (again from the punch card days).

Thanks for the feedback, and I incorporated some changes based on your 
previous comments.

On Thu, 30 Sep 2021, Ed Czarnecki wrote:
> Hi Sean - please note that for a non-geographic testing code, 99xxxx
  (and 999999 specifically) in some systems/standards mean all sites within
  a broadcast or system coverage area.
>
> Just FYI.  However the idea of creating an official "dummy" test FIPS
  is otherwise a good one.