On January 10, 2012, the FCC released a Fifth Report and Order (R&O) on the Emergency Alert System (EAS), which contains new rules to integrate the Common Alerting Protocol (CAP) into EAS as well as other rule changes that are non-CAP related; those rules took effect on April 23, 2012. Many State Emergency Communications Committees (SECCs), the volunteer-staffed committees that usually maintain the State EAS Plan in each state, are considering whether now is the time to begin the process of bringing their state plan into alignment with the new FCC EAS rules. As a State EAS Broadcast Chair myself, I would encourage SECCs to at least begin the process at this time, but consider some caveats.

An excellent article on this topic entitled “States Ready to Revise EAS Plans” has already been published by our friends at Radio World Magazine. Author Randy J. Stine does a good job of presenting where some states are at in revising their State EAS Plan, and the trepidations of others. The last deadline for EAS CAP is June 30, when broadcasters and cable operators will be required to have equipment installed to receive EAS alerts in the CAP format. Also by that date, these EAS Participants must have their EAS-CAP unit connected to the Internet and monitoring the FEMA EAS CAP feed described in the new FCC EAS rules. I agree with the Radio World article that most states will not have a revised State EAS Plan ready by that date, especially since those revised plans must be submitted to and approved by the FCC before they are effective. It is my understanding that no revised State EAS Plans have yet been submitted to the FCC for their consideration. I have also been told, as the Radio World article advises, that the FCC intends to release guidance for revising State EAS Plans; I was given no timeline for the release of this information, but it will be most welcome by all SECCs.

One other consideration in revising State EAS Plans is that the FCC deferred a decision on a number of items outlined in the Fifth R&O until after it completes its analysis of the Nationwide EAS Test results. Those deferred decisions deal with a few items that may need to be addressed in a revised State EAS Plan, such as whether there will be an EAS Location Code to represent the entire United States ( code 000000 has been suggested), if the FCC EAS Mapbook and EAS Operating Handbook will be retained and if so in what form, possible changes to the Required Weekly Test (RWT) and Required Monthly Test (RMT), whether manual operation should be allowed for processing the President’s Emergency Action Notification (EAN) code, and finally the FCC is considering changes to the rules addressing the SECC and the State EAS Plan itself.

Wisconsin's EAS Plan

So what is an SECC to do? My recommendation, and what I have currently started on, is to initiate revising your State EAS Plan right now beginning with the low-hanging fruit as it were. All State EAS Plans that haven’t been updated in a while need the usual check on SECC member contact information, double-checking the call letters of key EAS stations referenced in the plan, and other housekeeping chores. Additionally, we are already aware of a laundry list of changes in the Fifth R&O FCC rule updates that may affect State EAS Plans, such as:

• The new requirement for all EAS Participants to monitor the FEMA EAS CAP feed.
• The EAS Attention Signal is to now be 8 seconds exactly.
• The Non-participating National (NN) station designation has gone away.
• The Emergency Action Termination (EAT) code has gone away.
• FIPS Codes are now called ANSI Numbers, although the codes themselves haven’t changed.
• Rule 11.44 EAS Message Priority (National, then Local, then State, then NIC) has gone away.

While additional new rules may emerge from the deferred items and the Commission may be releasing State EAS Plan guidance soon, these above known items can be addressed in an initial plan rewrite draft while we wait for the FCC’s other shoe to drop. States with a new CAP-based system to describe in their plan can likewise begin inserting that language in their draft plan. While it would seem premature to submit a revised State EAS Plan to the FCC at this time, this lull is certainly an opportune moment to address the items we do know will need updating.

In an effort to assist SECCs in rewriting their plans, our friends at the Broadcast Warning Working Group’s (BWWG’s) EAS Forum have posted a sample State EAS Plan. This effort started with a meeting of SECC members and other interested parties at NAB2012, and has continued online with numerous upgrades and improvements. I urge all SECCs to at least review this sample plan for content to include in their current plan even if they are not looking to adopt the exact format of the sample plan.

State EAS Plan rewrites are definitely in an initial stage right now – stay tuned to AWARE for further developments. In the meantime, feel free to leave your comments to this post.