AWARE staff writer Gary Timm contributed to this article.

Earlier this week, AWARE published an article summarizing several of the presumed priorities David Turetsky, the new bureau chief of the Federal Communications Commission’s (FCC) Public Safety and Homeland Security Bureau.  Today, AWARE proposes several additional public alert and warning priorities Mr. Turetsky should consider as he moves forward in his new role with the FCC.

CMAS Priorities

Back in December, AWARE asked if it was time to revisit the recommendations developed by the Commercial Mobile Service Alert Advisory Committee (CMSAAC) in December 2007 to support the launch of the Commercial Mobile Alert Service (CMAS).  Given the fact that the CMSAAC last convened in 2007 and CMAS has since deployed in April 2012, Mr. Turetsky should consider reconvening the CMSAAC within the next one to two years to assess the now-live CMAS system as a whole and the recommendations the committee put forward for the system.  In addition to (or independent of) reconvening the CMSAAC, Mr. Turetsky also should consider revisiting three key areas of the FCC’s own rules and orders for CMAS, which were based upon the CMSAAC recommendations.

Enhancing the Precision of Geo-Targeted Alerts

First, Mr. Turetsky may want to consider the value of adding to the FCC’s Part 10 CMAS rules a requirement that all carriers participating in CMAS implement the ability to target alerts to the individual tower level by a future date, such as December 31, 2014.  In fact, some carriers have stated that they have already implemented this level of granularity into parts of their infrastructure.  However, when this level of precise targeting is not uniformly implemented by all participating carriers in a jurisdiction, the value to first responders is questionable.  First responders who have completed or are currently in the process of adopting CMAS have noted that they face the quandary of:

  1. Only targeting CMAS alerts at the county level until all participating carriers in the jurisdiction are able to geo-target below the county level consistently, or
  2. Actually choosing to issue alerts below the county level when applicable and facing the challenge of composing CMAS alert language appropriate for dissemination at the entire county level by some carriers, as well as at the tower level by other carriers.

The implementation of a finer granularity is not a simple task for the carriers, but if CMAS is to improve its capabilities and diminish over-warning citizens who are not directly impacted by an event within the county, then this change by the FCC is necessary.

As part of any FCC rule change, the Commission would need to issue a Notice of Proposed Rulemaking (NPRM) where all parties can file comments on the impacts of the new, proposed rule.  This would afford the opportunity for alert originators and carriers to state any perceived benefits or pitfalls of a recommendation to geo-target CMAS alerts below the county level.

Permitting Local Weekly CMAS Tests to Handsets

Second, AWARE recommends Mr. Turetsky consider the possibility of amending Part 10 CMAS rules to allow state and local authorities to test CMAS regularly, potentially by allowing use of the “RWT” testing code as a pass-through to handsets.  In December 2007, the CMSAAC was against CMAS testing to handsets. However, some alert originators who have completed the CMAS adoption process have noted the value of testing and presumably are more in tune with what their own jurisdictions may find to be acceptable test activities than the CMSAAC’s blanket opinion against the display of routine test messages on handsets.

Given the CMSAAC’s initial opposition, it may be beneficial to see this change as a Proposed Rule in an FCC NPRM in order to allow all concerned parties to submit public comments to the Commission, as opposed to relying on a small body of CMSAAC members to address it.  Such a change regarding testing would likely require the distribution to alert originators of guidance regarding outreach, coordination with carriers, data collection, and other planning actions to support execution of these tests in a fashion that maximizes their value and minimizes disruption to all parties involved.

Conducting an Annual End-to-End Test of CMAS

Third, AWARE recommends Mr. Turetsky consider one final change to the Part 10 CMAS rules:  requiring an annual end-to-end test of CMAS nationwide.  This would enable the public to observe how CMAS alerts display on their mobile devices and also provide an opportunity for all parties involved in CMAS, including the FCC, FEMA, carriers, and mobile device manufacturers to confirm the system is working, identify any flaws in the system, and monitor CMAS-enabled mobile devices to ensure they display national-level alerts properly.  Such an annual nationwide test of CMAS also aligns with FEMA and the FCC’s recommendation to conduct an annual Nationwide EAS Test.

EAS Priorities

Apart from the Part 10 CMAS rules, one final consideration for Mr. Turetsky is related to the FCC’s Emergency Alert System (EAS) Fifth Report and Order released on January 10, 2012.  In this report, the Commission deferred decisions on a number of EAS issues “until after we have reviewed and processed the test data from the November 9, 2011, Nationwide EAS Test”.

We are now approaching the one-year mark since the Nationwide EAS Test took place. The FCC should release its findings on this test as soon as possible to not only shed light on what the FCC learned in the test, but also to allow forward progress on possible EAS rule changes—progress which has been in limbo since the start of 2012. These new rules most likely will impact the rewrite of State EAS Plans, which the FCC has asked that State Emergency Communications Committees (SECCs) currently be engaged in. Without knowledge as to which of the possible deferred rules may be implemented, SECCs may need to rewrite their plans yet again, as soon as the Commission rules on the possible future EAS rule changes.

Mr. Turetsky has presented on his main priorities as the Public Safety and Homeland Security Bureau Chief before several alert and warning stakeholder organizations over the last few months, and AWARE expects his outreach to stakeholders will continue as we head into “conference season” early next year.  We at AWARE hope to hear more about Mr. Turetsky’s priorities and plans for CMAS and EAS, in particular, during these events – and we hope our readers, too, will have the opportunity to share their own insights and recommendations with Mr. Turetsky during future gatherings and conference events.

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