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

[Sean Donelan]

It looks like the ECFS indexers have caught up, and 9 submissions found.

8 out of 9 submitted comments about Persistent Alerts.  Smattering of 
comments on the other questions. Mr. Timm submitted publishing corrections 
of the rules. Mr. Donelan also submitted recommendations for other 
improvements.

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

Adrienne Abbott, Nevada SECC Chair
Edward Czarnecki, Digital Alert Systems
Paul Davis, Xperi Holding Corporation
Sean Donelan, individual capacity
Rick Kaplan, et al, National Association of Broadcasters
Matthew M. Polka, et al, ACA Connects - America's Communications 
Association
Harold Price, Sage Alerting Systems
Andy Scott, et al, NCTA - The Internet & Television Association
Gary E. Timm, individual capacity

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, 
supports changing text, Restore EAN ORG code for use by non-presidential 
authorities
d.	Edward Czarnecki, Digital Alert Systems - Supports changing PEP 
code and/or associated text
e.	Andy Scott, et al, NCTA - The Internet & Television Association - 
Supports changing PEP code
f.	Matthew M. Polka, et al, ACA Connects - America's Communications 
Association - Not opposed to changing PEP code, requests sufficient time

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 EAN code, 
Can change text
b.	Sean Donelan, individual capacity - Opposes changing EAN code, Can 
change text
c.	Andy Scott, et al, NCTA - The Internet & Television Association - 
Opposes changing EAN code
d.	Edward Czarnecki, Digital Alert Systems - Opposes changing EAN 
code, supports changing associated text
e.	Matthew M. Polka, et al, ACA Connects - America's Communications 
Association - Opposes changing EAN code

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
c.	Andy Scott, et al, NCTA - The Internet & Television Association - 
Supports deleting NIC code
d.	Edward Czarnecki, Digital Alert Systems - Supports deleting NIC 
code
e.	Matthew M. Polka, et al, ACA Connects - America's Communications 
Association - Supports deleting NIC code

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 persistent alerts
b.	Harold Price, Sage Alerting Systems - Opposes persistent alerts
c.	Paul Davis, Xperi Holding Corporation - Supports persistent 
alerts, some HD radio models have alert history
d.	Rick Kaplan, et al, National Association of Broadcasters - Opposes 
persistent alerts
e.	Sean Donelan, individual capacity - Opposes persistent alerts in 
EAS, notes some consumer devices have alert history, suggests a 
non-routine "Cancel Alert" event code
f.	Andy Scott, et al, NCTA - The Internet & Television Association - 
Opposes persistent alerts
g.	Edward Czarnecki, Digital Alert Systems - Opposes mandating 
persistent alerts, suggest industry given time to consider realistic 
alternatives
h.	Matthew M. Polka, et al, ACA Connects - America's Communications 
Association - Opposes persistent alerts

7.	Housekeeping suggestions
a.	Gary E. Timm, individual capacity - Several editorial and errata 
corrections to the published rules
b.	Sean Donelan, individual capacity - Several editorial and errata 
corrections to the published rules