The BDR

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If not Governor Must Carry, Then What?
By Richard Rudman

[January 2012]

Within hours of the BWWG filing our ex parte Comments on the governor must carry issue (GMC), the FCC released its Fifth Report and Order saying that GMC will be taken out of the Rules. Since CAP carriage of any EAS events will not take effect until June 30, GMC never really happened. Some states had thought about how they were going to do it, but now, it's back to the drawing board as we see it to figure out how to get everyone on board for voluntary carriage.

Phase One of that process will be to get entities subject to Part 11 (as well as state and local warning centers) together into representative and functional SECC's and LECC's.

Phase Two will require hammering out agreement on five elements we described in the BWWG ex parte filing:

1. Event specificity: the mandatory alert capability should be linked to an existing event code.  The CAP-EAS Implementation Guidelines adopted by FEMA make a provision for "tagging" an existing event code with the mandatory carry override.

2. Usage threshold:  Emergency Managers should help us define what circumstances would justify use of an “event-driven must carry” capability.  Emergency managers and other EAS stakeholders can define safeguards that can be put into place to prevent over-use or abuse and suggest sanctions that can be put in place in case of abuse.

3. Designated authority:  While this could certainly use further definition, many infer that the designated civil authority would be a qualified, professional emergency manager determined the same way that governors now designate normal emergency management functions. It should also recognize the National Weather Service as a valid warning partner within the overall framework of professional emergency management.   While this is implicitly understood by all states, it could and should be made explicit, either in the revised FCC regulations, or as part of a standardized practice all stakeholders would agree to, as well as part of the rewrite of local and state plans.

4. Need for standardized operational practice:  EAS stakeholders must work in concert on an ongoing basis to forge best practices, monitor their deployment, and make adjustments when warranted. We suggest that these best practices should be introduced into state EAS plans to maintain consistency from state to state in use of any mandatory alert capability.  Recommending a Standard Operating Practice (SOP) for “event-driven must carry” should be an immediate goal of the proposed DHS National Advisory Council that could come into being as a result of Congressional actions in progress.

5. Need for standardized training:  Standardized training and testing and exercise design for the warning components of local and state emergency management beyond FEMA’s new IS-247 should be encouraged. Such training should reinforce how an “event-driven must carry” capability should be (and not be) used. FEMA and the Commission both need to find a way to work with these systems (and vendors) in a public-private partnership role as part of a new and badly needed overall EAS stakeholder partnership.

The BWWG believes that decisions related to these five points should become key elements in state and local EAS plans. Lots of decisions, but the end result will be worth the effort, leading to better overall emergency response to get timely warnings containing accurate protective information to more people at risk.

FEMA and their IST247 training and certification will be a major lever to make all this possible. The BWWG feels that an important element in forming effective local and state committees will be for broadcasters to learn more about emergency management. Does IST247 fully do what the BWWG thinks is needed? No. We believe that the growing trend to turn information into a true, full resource in the tool kit for emergency managers more has to be done.

When emergency managers everywhere treat warnings as a key element of first response, we will be a lot closer to winning the hearts and minds of Part 11 entities so they will willingly volunteer to carry all EAS events in their local EAS plans. If this happens, people at risk will receive better, timely warnings that can help save more lives and property.

The BWWG encourages subscribers to the EAS Forum to chime in, pro or con. We look forward to hearing what you have to say.

More information and an EAS mailing list is at https://eas.radiolists.net

Nautel


 

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