REC response to the FCC regarding EAS, WEA, filing burdens, etc.

PS Docket 25-224, an NPRM which should be a NOI deep dives into the future of EAS and WEA.

REC Networks has filed comments in PS Docket 25-224. While this proceeding was considered a Notice of Proposed Rulemaking, there are no rules being proposed to be changed. This should have been a Notice of Inquiry and that’s how we are treating it.

This proceeding was a general inquiry on the Emergency Alert System (EAS) and Wireless Emergency Alerts (WEA) and looking for ways it can be improved. As a part of the inquiry, the FCC did have some specific questions.

A summary of points and positions made by REC in this proceeding included:

• That the Carr Administration immediately roll back enforcement of the requirements that radio broadcast stations use an EAS decoder that is capable of “CAP Polling”. CAP Polling is a technology where if a message is first received over the radio, it will wait for up to 10 seconds for that same message to come over the internet (IPAWS). If a duplicate IPAWS message comes in, that’s the message that will forward. This functionality is very helpful for television because it allows for a more significant amount of content to be crawled on the screen, especially helping those with disabilities.

• That the Carr Administration immediately stop all development on the “template-based” multi-lingual EAS alert system proposed by the Rosenworcel Administration. We oppose it because it would be a significant burden on stations and software developers to equip EAS decoders with languages that are not even spoken on the radio in this country. REC feels that efforts, such as those in Los Angeles for Spanish language EAS is sufficient.

• That the Commission waive the rules and stop the practice of the annual filing of ETRS (EAS Test Reporting System) Form One on years where the FCC and FEMA do not conduct a National Periodic Test (NPT). This reporting requirement is burdensome and has not resulted in any public work product deliverables.

• State governments tend to create bureaucracies over who can send alerts into IPAWS. The consequences of this played in Delaware a few years ago.

• IPAWS-OPEN alert originators are too dependent on “macros” or what we call “speed dials” to create template alerts that have fixed targeting. Such targeting resulted in the entire state of Delaware being told to shelter in place due to a small industrial accident resulting in a real shelter in place for about 1 mile around the location. In Los Angeles, the entire county was told to evacuate when the actual evacuation was a small area north of Calabasas, CA. CAP has beautiful geographic capabilities that can be reflected when viewing WEAs.

• REC calls for radio stations, small radio stations, LPFM and TV broadcasters to be separate categories with separate requirements. No more “one size fits all”.

• Because of the recent CAP Polling mandate, small stations may still be feeling the burn on the expenses needed to make that replacement. REC has taken the position the “cost per listener” in order to either implement it or exempt certain stations from a future rule. Cost per listener is simply the amount of the project divided by the census population in the station’s 60 dBu service contour.

• The National Weather Service needs to step up and start using IPAWS-OPEN. REC does not want to see any changes to EAS requirements until this happens.

• Promoted the use of Partial County Alerting for counties with significant land area.

• Opposes private sector utility companies from getting access to IPAWS in order to originate alerts. The types of alerts a utility company would give can also be done by the local government. This access leaves open too many vulnerabilities and no accountability if the utility company, which may be a for profit business, uses EAS or WEA for marketing messages and interrupting tips.

• We question whether small stations (including LPFM) should even be required to have an EAS decoder.

• We note the bad results of the past NPTs, especially for areas that are outside the 2 mV/m contour of an AM station acting as a PEP.

• We call for FM translators in the reserved band (88~92) that are rebroadcasting a station using means other than over the air to be required to have an EAS decoder for their local area. The example we give is a FM translator in Maryland rebroadcasting a station in Idaho.

• We encourage alert originators to properly use the geographic targeting functionality in IPAWS including radius from a centroid, bounding boxes and polygons.

• We oppose any kind of complex cybersecurity process for small stations. Instead, we must promote good network practice (i.e. having your equipment behind a NAT, don’t make your password ‘123456’, etc.).

• We oppose any kind of alerting requirement on industries that are not directly within the purview of broadcasting, including websites, social media, etc.

A copy of REC’s filing can be found here:
https://recnet.net/fcc/25-224_comments.pdf

Reply comments due on October 10, 2025.