[sbe-eas] FCC Proposes Multilingual Alerting

[Aaron Read]

The individual stations actually worry me less than the various state
EMA's.  If I'm reading the draft NPRM correctly, what they're talking about
doing is basically adding a software flag to CAP that when a station sets
the flag for their language to be (something other than English) it will
poll the CAP servers to get audio in the language they have set it to.  I
can see plenty of issues with this system from the stations' end.  But god
help the poor EMA's that're already woefully undertrained and often
under-staffed and under-resourced, who now have to make sure every alert
that goes out is not only effectively coded, written, voiced and generally
appropriate for *English*, but now has to deal with 10 or 12 other
languages, too?  Yikes.

- Aaron


On Fri, Jan 26, 2024 at 11:29 AM Walke, Larry via sbe-eas <sbe-eas at sbe.org>
wrote:

> 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>
> 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
>
>
>
> [image: National Association of Broadcasters]
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> --
>
> ------------------------------------------
> Aaron Read
>
> readaaron at friedbagels.com
>
> www.friedbagels.com
>
> "Engineering: it's like math but LOUDER!"
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-- 
------------------------------------------
Aaron Read
readaaron at friedbagels.com
www.friedbagels.com
"Engineering: it's like math but LOUDER!"
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