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

[Sean Donelan]

It appears the only universal agreement was opposition to changing the 
"EAN" event code.  Some commenters made a distinction between changing the 
EAN code and changing the associated EAN text. Some were in favor of 
changing the text associated with the EAN, while keeping EAN event code 
unchanged.

There was almost universal opposition to persistent alerts.  Xperi 
appeared to support persistent alerts, but mostly discussed how HD Radio 
implements persistent alerts.  Donelan and DASDEC were against using 
EAS for persistent alerts, but suggested industry alternatives may be 
possible. Several mentioned the missing "Cancel Alert" problem with EAS 
persistent alerts. A similar "Cancel Alert" problem exists with WEA, but 
slightly different.

There was nearly universal support for deleting the "NIC" event code. 
Donelan was the only commenter to suggest FEMA needs a reserved 
'conventional' national event code for federal alerts (i.e. 2-minute 
limit, no-priority, pre-emption), in addition to the "EAN" which has 
special processing. I suggested either keeping NIC (i.e. compatibility 
with legacy weather radios) or adding a new national event code (NEM or 
NDW).

Changing the "PEP" orgination code (ORG) was split.  Half-opposed, 
half-supported changing PEP.  Most supported changing the associated text, 
whether or not the code itself changed. Some had questions about how the
change would happen. Donelan had a more complicated comment, with 
distinct ORG codes for the President (PEP) and other National Authorities 
(EAN).

Not part of the NPRM:

Donelan and Timm pointed out several typos and mistakes in the Part 11 
rules.

Donelan suggested several additional EAS improvements:
1) Add a non-routine "Cancel Alert" using the deprecated "EAT" event code 
for EAS and WEA use
2) Weather event code improvements to reduce EAS warning message "floods"
3) Prohibit "ducking" background audio during EAS messages
4) Non-Geographic Testing Location using (SS == "99")
5) Updating FIPS (INCITS) Location Codes
6) Improved and consistent testing rules for multi-stream and satellite 
EAS participants
7) Replacing antiquated requirement for national EAS handbook
8) CAP "Ack" messages for IPAWS operational feedback
9) Clarifying expected ORG, Event and Locations combinations (part of a CONOPS)