[sbe-eas] FCC Proposes Multilingual Alerting

[Dave Turnmire]

I find it interesting that the latter third of the document is labeled 
"Non-Public Draft"  🙁

Other comments/observations after a quick read:

  * Does existing EAS equipment have the storage capacity to accommodate
    these templates & associated audio files?It would appear that some
    amount of TTS would be required as the “templates” wouldn’t include
    key info such as location.The EAS equipment would thus require
    having the hardware and software resources to provide TTS for those
    14 languages.Or alternatively, that different versions of “firmware”
    be provided by vendors for each of the 14 languages to support
    broadcasters’ primary language.But what of broadcasters that
    broadcast primarily in one language, but broadcast in another
    language for significant periods of time?Presumably their EAS box to
    support more than one language (presumably not more than 2 or 3),
    for either “simultaneous” broadcast or language triggered by automation

    The FCC suggests as an alternative, that the templates leave out the
    location entirely and say something like “/A wildfire alert has been
    issued for your area. *Please contact local authorities* or check
    local news sources for more information./”.Hard to imagine that the
    “local authorities” would like everyone in their community calling
    them to ask IF the alert applies to them.Seems more likely that
    often the public will just ignore the message.
  * Does current cable system technology allow for sending out more than
    one version of an alert… English for most channels, but other
    languages for some?
  * EAS is NOT WEA.WEA is inherently limited in the amount of
    information that can be provided to the public EAS can provide much
    more(at best 360 characters, vs @1800). But that also will likely
    make it more difficult to come up with a template based alert that
    is as effective as the human generated alert… in the case of English.
  * Would originators be allowed to use a complete/accurate English
    version, while using the closest approximate for templates in other
    languages?Hard to imagine a template would provide as effective
    communications as a human generated version… albeit it would be
    better than the common scenario where there are NO non-English
    alerts.But the NPRM /appears/ to indicate that templates must be
    used for English as well as non-English.
  * Would the FCC provide legal protection to Government agencies for
    initiating alerts that they are unable to vet for accuracy?
  * We are STILL waiting for one prominent EAS product vendor to release
    software updates for the last FCC rule making.This one would appear
    to be much more complicated.It calls into question whether there are
    resource limitations at the equipment vendors that would make this
    an impractical change.And the commission seems to looking primarily
    at the labor costs for EAS Participants to install updates.It
    ignores the fact that broadcasters are already seeing sharply
    increased “costs of ownership” passed on by their vendors who are
    passing on the development costs imposed by the FCC.
  * Will these templates be updated/corrected by the FCC as rapidly as
    they have approved ARS submissions?😛

Dave

On 1/26/2024 7:59 AM, Walke, Larry via sbe-eas 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
>
> ...
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