[EAS] Comments on FCC 21-77 on FEMA requested changes to EAS

[Ed Czarnecki]

There should be a good number of additional filings listed on the site today, if organizations posted them towards COB yesterday (I know at least one more industry association filed detailed comments).  Digital Alert Systems filed comments as well yesterday.


From: EAS <eas-bounces at radiolists.net> on behalf of Sean Donelan <sean at donelan.com>
 
Comments submitted by 5 people/organizations

Adrienne Abbott, Nevada SECC Chair
Paul Davis, Xperi Holding Corporation
Sean Donelan, individual capacity
Rick Kaplan, et al, National Association of Broadcasters
Harold Price, Sage Alerting Systems

All submitted comments about Persistent Alerts.  Smattering of comments
on the other questions. FCC often cherry-picks comments supporting what
they already decided.

Lots of good information and justifications in the submissions. Read the
actual submissions for the details. Overly simplified and summarized as
follows:

1.      FEMA recommends the originator (ORG) code "Primary Entry Point
System," ORG Code "PEP," should be changed to "National Authority," ORG
Code "NAT."
a.      Adrienne Abbott, Nevada SECC Chair - Opposes changing ORG code,
notes public doesn't understand PEP code
b.      Harold Price, Sage Alerting Systems - Opposes changing ORG code,
Can change text
c.      Sean Donelan, individual capacity - Opposes changing ORG code, Can
change text, Restore EAN ORG code for use by non-presidential authorities

2.      FEMA recommends that the definition for event code EAN be either
changed to "Emergency Alert, National" or replaced with "National
Emergency Message," event code "NEM."
a.      Harold Price, Sage Alerting Systems - Opposes changing EEE code,
Can change text
b.      Sean Donelan, individual capacity - Opposes changing EEE code, Can
change text

3.      FEMA recommends deleting the term National Information Center
(NIC) in EAS rules.
a.      Harold Price, Sage Alerting Systems - Not opposed to deleting NIC
event code
b.      Sean Donelan, individual capacity - Repurpose NIC event code for
national alerts

4.      FEMA recommends changing the WEA alert category "Presidential" to
"National" alerts.
a.      Previous WEA rulemaking

5.      FEMA recommends that State Emergency Communications Committee
(SECC) functions be aligned with Statewide Interoperability Coordinator
(SWIC) functions and that State EAS Plans be incorporated into Statewide
Communication Interoperability Plans.
a.      Previous rulemaking

6.      FEMA recommends the FCC consider methods to update the EAS to
support persistent display of alert information and/or persistent
notification for emergencies that require immediate public protective
actions to mitigate loss of life.
a.      Adrienne Abbott, Nevada SECC Chair - Opposes, let the local
broadcasters do what they do best
b.      Harold Price, Sage Alerting Systems - Opposes
c.      Paul Davis, Xperi Holding Corporation - Supports, some HD radio
models have alert history
d.      Rick Kaplan, et al, National Association of Broadcasters - Opposes
e.      Sean Donelan, individual capacity - Opposes, notes some consumer
devices have alert history, suggests a non-routine "Cancel Alert" event
code

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