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

[Sean Donelan]

If you would like to see my draft comments on FEMA's recommended changes 
to EAS in FCC 21-77, please send me an email. Thanks to feedback from 
others, I've changed some of my recommendations already. And corrected 
some errors. Comments are due October 19, 2021.

>From FEMA's letter to FCC (FCC rewrote questions in the NPRM)

1. The originator (ORG) code "Primary Entry Point System," ORG Code 
"PEP," should be changed to "National Authority," ORG Code "NAT."

Alternative proposal to maintain interoperability with legacy and consumer 
equipment

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."

Alternative proposal to maintain interoperability to legacy and consumer 
equipment.

3. FEMA recommends deleting the term National Information Center 
(NIC) in EAS rules.

Alternative proposal for use with national alerts without triggering 
special EAN handling, maintain interoperability with legacy and consumer 
equipment.

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

Not part of this NPRM. Covered in previous 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.

Agree, with additional recommendations to publish Concept of Operations 
and eliminate EAS handbook.

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.

Disagree. Legacy EAS is wrong place for this. But goal is supported other 
ways (other tools in alerting toolbox).

7. Comments regarding Reporting of False Alerts.

Proposal for an informational Cancel Alert for non-routine erroneous 
alert.

Finally, I suggest additional improvements to the EAS and technical 
errata.

A) Weather event code improvements to reduce EAS warning message "floods"
B) Prohibit "ducking" background audio during EAS messages
C) Non-Geographic Testing Location using (SS == "99")
D) Improved and consistent testing rules for multi-stream and satellite EAS participants
E) Replacing antiquated requirement for national EAS handbook
F) CAP "Ack" messages for IPAWS operational feedback
G) Clarifying expected ORG, Event and Locations combinations (part of CONOPS)