[sbe-eas] FCC Proposes Multilingual Alerting

[Walke, Larry]

Yes, the FCC has zero idea of how much this would actually cost, and assumes that it would be a free and easy software upgrade. And makes no mention of the fact that many of the stations it is trying to target, foreign-language stations, may be small and least able to afford to implement its proposal.


Larry Walke, NAB Legal & Regulatory
(202) 429-5313 (o)
(202) 607-7611 (c)

From: sbe-eas <sbe-eas-bounces at sbe.org> On Behalf Of Aaron Read
Sent: Friday, January 26, 2024 11:06 AM
To: SBE EAS Exchange - a mail list for discussion about the Emergency Alert System and other emergency communication issues. <sbe-eas at sbe.org>
Subject: Re: [sbe-eas] FCC Proposes Multilingual Alerting

EXTERNAL EMAIL:

Did anyone else see this cost estimation and think that, A: it's total gobbleygook, and B: it's wildly underestimating the difficulty (and therefore higher cost) of implementing and testing operations involving non-native languages?

- Aaron


37. Assuming that template alert processing can be implemented via a regular software update patch that EAS Participants install in the normal course of business, we would expect the costs of software installation, labor, and testing to install the patch likely would be similar to the industry-wide estimate for mandatory software updates in the Comprehensible Alerts Order. The Commission estimates that software labor industry-wide would not exceed 5 hours of labor multiplied by 25,519 estimated broadcasters and cable head-ends, plus 1 SDARS provider and 2 DBS providers, for a total of 127,610 hours of software-related labor, a figure which is likely an over-estimate. Using an average hourly wage of $60.07 for software and web developers, programmers, and testers, and factoring in a 45% markup of hourly wage for benefits, and a 5.5% inflation adjustment between 2022 and 2023,we estimate an hourly wage of $91.89.89 Using these estimates of 5 hours labor time at a cost of $91.89 per hour would result in a total labor cost to each EAS Participant for installing a software patch that configures the template mechanism in the EAS device of approximately $460, and an aggregate labor cost of approximately $12 million. We seek comment on whether this estimate is too high or too low, and we ask commenters to provide data supporting either our cost estimate or a different estimate.

On Fri, Jan 26, 2024 at 9:59 AM Walke, Larry via sbe-eas <sbe-eas at sbe.org<mailto:sbe-eas at sbe.org>> wrote:
The FCC has published a draft NPRM that proposes to increase the use of multilingual EAS alerts using language templates. Any initial thoughts on the technical feasibility, cost, etc of the FCC’s proposal would be appreciated.  https://docs.fcc.gov/public/attachments/DOC-400038A1.pdf


Larry Walke
Associate General Counsel
Legal & Regulatory

[National Association of Broadcasters]

1 M Street SE
Washington DC  20003
Phone 202 429 5313
Mobile 202 607 7611
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--
------------------------------------------
Aaron Read
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www.friedbagels.com<http://www.friedbagels.com/>
"Engineering: it's like math but LOUDER!"
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