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Commission Document Attachment

DOC-320152A2

Strengthening the Emergency Alert System (EAS):

Lessons Learned from the Nationwide EAS Test

April 2013

Federal Communications Commission

445 12th Street, SW

Washington, DC 20554


Federal Communications Commission

TABLE OF CONTENTS

Heading
Page
I. EXECUTIVE SUMMARY.................................................................................................................... 3
II. INTRODUCTION.................................................................................................................................. 5
III. BACKGROUND.................................................................................................................................... 6
A. The Emergency Alert System Architecture and the Need for Nationwide Testing......................... 6
B. The Road to the First Nationwide EAS Test.................................................................................... 8
IV. NATIONWIDE EAS TEST RESULTS............................................................................................... 10
A. Overview........................................................................................................................................ 10
B. Breakdown of Test Performance by EAS Participant Category .................................................... 10

1. National Primary (PEP) Stations............................................................................................. 12
2. Local Primary Stations (LPs) .................................................................................................. 12
3. Participating Nationals ............................................................................................................ 13
C. Performance by Classes of EAS Participant .................................................................................. 13
1. Broadcasters ............................................................................................................................ 13
2. Cable Providers and Wireline Video Service Providers.......................................................... 13
3. Satellite Systems...................................................................................................................... 13

V. EQUIPMENT PERFORMANCE ........................................................................................................ 13
VI. MOST SIGNIFICANT LESSONS LEARNED ................................................................................... 13
VII. A PATH FORWARD TO STRENGTHENING THE EAS................................................................ 16
VIII. CONCLUSION .................................................................................................................................. 19
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I.

EXECUTIVE SUMMARY

On November 9, 2011, at 2:00 p.m. Eastern Standard Time (EST), the Federal Communications
Commission (“FCC” or “Commission”) and the Federal Emergency Management Agency (“FEMA”)
conducted the first-ever nationwide test of the Emergency Alert System (“EAS”). Thousands of
broadcasters, cable operators, and other EAS Participants1 took part in the test, which involved the
simultaneous receipt and broadcast of a live national EAS alert to all EAS Participants across the United
States and its territories. The purpose of the test was to allow the FCC and FEMA to assess how the
national EAS architecture would perform in practice, and to develop and implement any necessary
improvements to ensure that the EAS, if activated in a real emergency, would perform as designed. The
test was the result of approximately two years of planning and preparation, involving the FCC, FEMA
and other Federal agencies, EAS Participants and their organizations, state and local governments,
consumer groups and organizations representing people with disabilities.
Prior to the test, the Commission completed a rulemaking to set the ground rules for the test and
authorized the Public Safety and Homeland Security Bureau (PSHSB or Bureau) to implement the test’s
operational details. The Bureau subsequently issued a series of public notices apprising EAS Participants
of the test’s requirements. In coordination with FEMA and industry stakeholders, the Bureau conducted
extensive outreach to ensure that all EAS Participants were aware of the test and the operational details
concerning their participation, and that the test would not cause any public confusion. The Bureau also
created a database that would allow EAS Participants to file their required reports electronically, and
would facilitate the Bureau’s analysis of the test’s results. The Bureau received and analyzed test result
data from over 16,000 EAS Participants, and held discussions with EAS Participants, FEMA and other
EAS stakeholders to analyze the test’s results. This report summarizes the lessons learned from the test
and the Bureau’s recommendations for strengthening the EAS.
Overall, a large majority of the EAS Participants successfully received the Emergency Action
Notification (EAN), the live code for the national EAS, and, if required, retransmitted the EAN to other
EAS Participants. The test demonstrated that the national EAS distribution architecture is basically
sound. As expected, however, the test uncovered several problems that impeded the ability of some EAS
Participants to receive and/or retransmit the EAN. These included:2
 Widespread poor audio quality nationwide;
 Lack of a Primary Entry Point (PEP) in the area to provide a direct connection to FEMA;
 Use of alternatives to PEP-based EAN distribution;
 The inability of some EAS Participants either to receive or retransmit the EAN;
 Short test length; and
 Anomalies in EAS equipment programming and operation.

1 The EAS uses the transmission facilities of radio and television broadcast stations, cable operators, satellite radio
and television service providers, and wireline video service providers (collectively referred to as “EAS
Participants”). See 47 C.F.R. §11.2(c).
2 Following a request from the Alaska Department of Homeland Security, the FCC granted Alaska EAS Participants
a rule waiver to excuse their performance in the Nationwide EAS Test due to severe weather conditions. Alaska’s
non-participation had minimal impact on the test because FEMA and the FCC received EAS data from Alaska as a
result of the two preliminary EAS tests FEMA and the FCC conducted there in 2010 and 2011. Notwithstanding
this waiver and as indicated below, Alaska did provide some data in connection with the November 9, 2011 test,
which data was used to develop the aggregate analyses contained in this report.
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The Bureau recommends that another nationwide test be conducted after the Commission takes a number
of steps to strengthen the EAS, including:
1) Commencing a rulemaking proceeding to examine equipment performance issues during
activation of an EAN and seek comment on proposed changes, if any, to the EAS equipment rules
to ensure that EAS equipment operates in a consistent fashion throughout the EAS architecture.
2) Issuing a Public Notice encouraging states to review and as necessary update their EAS plans to
ensure that they contain accurate and up-to-date information regarding monitoring assignments as
required by FCC rules.
3) Commencing a rulemaking proceeding to consider possible changes to its EAS plan rules.
4) Working with FEMA to develop and issue best practices and other educational materials for EAS
Participants, and, also with FEMA, consider hosting a workshop or other public forum that could
provide opportunities to educate EAS Participants about EAS performance and address concerns
and questions EAS Participants may have about EAN operations.
Turning to the issue of nationwide EAS testing, the Bureau recommends that the Commission take the
following actions:
1) Commencing a rulemaking proceeding to address any operational nationwide EAS test issues left
open in previous EAS orders, such as a possible nationwide location code for national EAS
activations, use of the National Periodic Test code or other test code that would allow FEMA and
the FCC to conduct less disruptive nationwide tests; and future use of the EAS Operation
Handbook.
2) Developing a new Nationwide EAS Test Reporting System database to improve electronic filing
of test result data by EAS Participants.
3) Encouraging the Executive Office of the President to reconvene the Federal EAS Test Working
Group to ensure accountability as Federal partners and other stakeholders work to implement the
lessons learned from the first test and to plan for future nationwide tests.
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Federal Communications Commission

II.

INTRODUCTION

On November 9, 2011, at 2:00 p.m. Eastern Standard Time (EST), the FCC and FEMA conducted a
nationwide test of the EAS. This event marked the first time the EAS (or its predecessor the Emergency
Broadcast System (EBS)) had been tested on a nationwide basis. The test involved the simultaneous
receipt and broadcast of a live national EAS alert by thousands of broadcasters, cable operators and other
media-based communications service providers across the United States and its territories.
The purpose of the test was to allow FEMA and the FCC to assess whether the national EAS would
perform as designed, if activated. The FCC and FEMA used this test, diagnostic in nature, to assess the
performance of the national EAS architecture and, to the extent the system did not perform as designed,
take corrective actions to ensure that the system functions as intended.
This test was the result of approximately two years of planning and preparation involving the FCC,
FEMA, the National Oceanic and Atmospheric Administration (NOAA) (and its component agency the
National Weather Service (NWS)), the Executive Office of the President, EAS Participants and their
industry associations, state and local governments and their organizations, consumer groups and
organizations representing people with disabilities. These efforts included development of a test plan and
live code EAS tests in the State of Alaska, an FCC proceeding to adopt rules governing nationwide EAS
tests, and various FEMA-FCC outreach efforts targeting EAS Participants, state and local governments
and consumers.
On November 9, 2011, FEMA successfully initiated the Emergency Action Notification (EAN), the live
code used for Presidential activations of the nationwide EAS.3 The Bureau subsequently has collected
and analyzed thousands of reports, including some that came in as recently as November 2012, held
discussions with FEMA and other stakeholders to analyze the data contained in these reports, and
participated in webinars and other fora where we discussed best practices that would help address some of
the issues uncovered by the test.
The EAN was successfully distributed throughout the majority of the system and overall, a large majority
of EAS Participants successfully received the EAN, and, if required, retransmitted the EAN to other EAS
Participants. Accordingly, the FCC and FEMA concluded that the nationwide EAS distribution
architecture is basically sound. As anticipated, however, this first ever diagnostic test also revealed a
number of problems that impeded the ability of some EAS Participants to receive and/or retransmit the
EAN. Although one problem, poor audio at the Primary Entry Point (PEP) level,4 may have affected
EAN distribution in some areas of the country, most problems were localized to equipment at individual
EAS Participants. To the extent such problems occurred high in the distribution chain,5 other EAS

3 The EAN is followed by an audio transmission of Presidential Messages. See 47 C.F.R §§ 11.13, 11.44. Only the
President may issue an EAN for a Presidential alert, and no President has ever done so.
4 Primary Entry Point (PEP) Stations are private or commercial radio broadcast stations that cooperatively
participate with FEMA to provide emergency alert and warning information to the public prior to, during, and after
incidents and disasters. The FEMA PEP stations also serve as the primary source of initial broadcast for a
Presidential or National EAS message. This select group of geographically distributed, independently powered, and
electromagnetic pulse (EMP) hardened radio stations collectively can reach over 90% of the American populace.
5 The EAS is distributed among the broadcasters, cable providers and other EAS participants by a broadcast-based,
hierarchical architecture commonly known as the EAS “Daisy Chain.” This distribution architecture is described in
detail in section III.A, infra.
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Participants were affected. In this report, we discuss these problems and offer recommendations for
actions the FCC should take to address them as well as next steps in advance of another nationwide test.

III. BACKGROUND

A.

The Emergency Alert System Architecture and the Need for Nationwide Testing

The EAS is designed primarily to provide the President with the capability to communicate via a live
audio transmission to the public during a national emergency.6 The EAS is the successor to prior national
warning systems: Control of Electromagnetic Radiation (CONELRAD), established in 1951; and the
EBS, established in 1963.7
The type of national emergency that would justify a Presidential EAS alert would be a catastrophic event,
where access to electrical power and communications systems may be significantly degraded or even
eliminated. Under such conditions, the one communications media platform likely to continue operating
is broadcast radio, accessible from battery powered consumer receiver sets and other means, such as car
radios and hand-cranked radios. Accordingly, the EAS was designed to provide a simple live audio feed
from the President, delivered initially to PEP radio stations. As indicated below, other EAS Participants
receive and, in turn, transmit the alert via the hierarchical broadcast-based EAS distribution system to
consumers.
The FCC, in conjunction with FEMA and the NWS, implements EAS at the federal level.8 The respective
roles these agencies play are defined by a 1981 Memorandum of Understanding between FEMA, NWS
and the FCC;9 a 1995 Presidential Statement of EAS Requirements;10 and a 2006 Executive Order.11 As a
general matter, the Commission, FEMA and NWS all work closely with radio and television broadcasters,
cable providers, and other EAS Participants and stakeholders – including state, local, territorial and tribal
governments – to ensure the integrity and utility of the EAS.

6 See Review of the Emergency Alert System, Second Further Notice of Proposed Rulemaking, 25 FCC Rcd at 564,
565, ¶ 2 (2010).
7 CONELRAD was not an alerting system per se, but was rather a Cold War emergency system under which most
radio and television transmission would be shut down in case of an enemy missile attack to prevent incoming
missiles from homing in on broadcast transmissions. The radio stations that were allowed to remain on the air, the
CONELRAD stations, would remain on the air to provide emergency information. See “Defense: Sign-off for
CONELRAD,” Time Magazine, Friday, July 12, 1963.
8 FEMA acts as Executive Agent for the development, operation, and maintenance of the national-level EAS. See
Memorandum
, Presidential Communications with the General Public During Periods of National Emergency, The
White House (September 15, 1995) (1995 Presidential Statement).
9 See 1981 State and Local Emergency Broadcasting System (EBS) Memorandum of Understanding among the
Federal Emergency Management Agency (FEMA), Federal Communications Commission (FCC), the National
Oceanic and Atmospheric Administration (NOAA), and the National Industry Advisory Committee (NIAC),
reprinted as Appendix K to Partnership for Public Warning Report 2004-1, The Emergency Alert System (EAS): An
Assessment.
10 See 1995 Presidential Statement.
11 See Public Alert and Warning System, Exec. Order No. 13407, 71 Fed. Reg. 36975 (June 26, 2006) (Executive
Order
).
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Federal Communications Commission

FCC rules require EAS Participants to have the capability to receive and transmit Presidential alerts
disseminated over the EAS, and generally govern all aspects of EAS participation.12 A Presidential alert
has never been issued, and prior to November 9, 2011, the national alerting capability of the EAS had
never been tested. Although EAS Participants also voluntarily transmit thousands of alerts and warnings
issued annually by the NWS and state, tribal, and local governments, these alerts typically address severe
weather threats, child abductions, and other local emergencies. As discussed in more detail below, non-
Presidential EAS alerts do not require that EAS Participants open a live audio feed from the alerting
source, but rather deliver alerts with prerecorded messages that can be delivered at the discretion of the
EAS Participant, rendering non-Presidential alerts (and their related testing procedures) inappropriate for
the test of a national alert.13
As illustrated below, the EAS architecture is designed to cascade the EAN through a pre-established
hierarchy of broadcast, cable, and satellite systems:
Figure 1. EAS Architecture

12 See 47 C.F.R. Part 11.
13 The EAS was subject to a patchwork of testing regimes that assessed components of the EAS, but not the national
EAS as a whole. For example, under FCC rules, EAS Participants are subject to weekly and monthly EAS testing at
the state and/or local level. FEMA regularly tests the connectivity between it and PEP stations. Meanwhile, NWS
tests its own National Weather Radio (NWR) facilities independently or as integrated with state and local
emergency alert delivery architectures. Finally, state officials maintain and test their own state Emergency
Operations Centers. As the Commission noted in February 2011, none of these operations involve top-to-bottom
national testing of the EAS architecture and thus “may not expose vulnerabilities in functioning or gaps in
nationwide coverage of the EAS.” See Review of the Emergency Alert System, EB Docket No. 04-296, Third
Report and Order,
26 FCC Rcd 1460, 1465 ¶ 9 (2011) (Third Report and Order).
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Federal Communications Commission

FEMA initiates a nationwide, Presidential alert using specific encoding equipment to send a special code,
the EAN,14 to the PEPs over a secure telephone (wireline) connection. Upon receipt of the code, the PEPs
open a live audio channel to FEMA and broadcast the EAN throughout their listening areas. A group of
selected EAS Participants in each PEP’s broadcast area, known as Local Primary (LP) stations, monitor
these PEP stations. When LP stations receive the EAN, they begin to buffer the audio message and re-
broadcast the EAN and audio message in their listening areas. The remaining broadcasters, cable
television facilities and other EAS Participants located in each LP’s broadcast footprint receive the EAN
alert from the LP stations, and in turn, begin to buffer and re-broadcast the EAN alert and audio message
to the public (or in the case of cable, to customers’ set top boxes). Once this process is complete (which
can take approximately 40 seconds), all EAS Participants are broadcasting the audio message from the
President across the entire nation.15 Each EAS Participant’s EAS designation and monitoring assignment
is described in state EAS plans, which are developed voluntarily by State Emergency Communications
Committees (SECCs), volunteer committees usually comprised of state broadcasters and state emergency
management officials. The SECCs make technical and operational recommendations to state and local
area authorities involved in emergency communications, write EAS plans for their state, serve as liaison
with the FCC’ and maintain liaison with appropriate industry committees at the national, state and local
levels.16

B.

The Road to the First Nationwide EAS Test

The road to the first nationwide EAS test began in the summer of 2009 when FCC Chairman Julius
Genachowski instructed PSHSB to conduct a 30-Day Review on FCC Preparedness for Major Public
Emergencies. In a September 2009 report,17 the Bureau noted that concerns had been raised regarding the
frequency and scope of EAS testing, and recommended that the three Federal agencies responsible for the

14 The EAN and other EAS codes are part of the Specific Area Message Encoding (SAME) protocol used both for
the EAS and NOAA weather radio. See National Weather Service, “NOAA Weather Radio All Hazards,” available
at http://www.nws.noaa.gov/nwr/same.htm
(last accessed March 28, 2013).
15 Many LP stations also play a primary role in distributing state-originated EAS alerts, and in that context they are
known as State Primary (SP) or State Relay (SR) stations. EAS Participants that are not monitored by other EAS
Participants but solely broadcast the alert to the public are known as Participating Nationals (PN). At the time of the
November 9, 2011 test, FCC rules permitted EAS Participants to be categorized as Non-Participating Nationals
(NN). NNs were not required to participate in national alerts but instead were required to go off the air if an EAN
were issued. Under FCC rules, NNs were required to maintain EAS equipment and participate in weekly and
monthly tests of the EAS. Because it was far easier for NNs to participate in the Nationwide EAS Test than to go
off the air, most NNs chose to participate in the Nationwide EAS Test as PNs. In January 2012, the Commission
eliminated the NN category in its EAS Fifth Report and Order as a technically obsolete holdover from the older EBS
alerting system. See Review of the Emergency Alert System; Independent Spanish Broadcasters Association, the
Office of Communication of the United Church of Christ, Inc., and the Minority Media and Telecommunications
Council, Petition for Immediate Relief; Randy Gehman Petition for Rulemaking
, Fifth Report and Order, EB Docket
No. 04-296 (rel. Jan. 12, 2012) (Fifth Report and Order). We collected data from NNs only to the extent that they
took part in the test.
16 See Amendment of Part 73, Subpart G, of the Commission’s Rules Regarding the Emergency Broadcast System,
Report and Order and Further Notice of Proposed Rulemaking, 10 FCC Rcd 1786, 1834 (1994) (First Report and
Order
).
17 See FCC Preparedness for Major Public Emergencies Chairman’s 30 Day Review, prepared by the Public Safety
and Homeland Security Bureau (Sept. 2009) (Chairman’s Review) at 24, available at
http://www.fcc.gov/document/chairman-genachowskis-thirty-day-public-safety-review-fcc-preparedness-major-
public-emergen (last accessed March 28, 2013).
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Federal Communications Commission

EAS – the FCC, FEMA and NWS – review the testing regime to see where improvement could be
made.18 In response, the FCC, FEMA, NWS and the Executive Office of the President convened a
working group to plan and conduct nationwide testing of the EAS. As an initial step, in January 2010 and
again in January 2011, FEMA, along with the FCC, the State of Alaska, and EAS Participants in Alaska,
conducted limited live testing of the EAN in Alaska. FEMA, the FCC and other Federal agencies used
the results of those tests to develop a test plan for the first nationwide EAS test.
In February 2011, the FCC adopted rules that authorized nationwide EAS testing, and established basic
procedures for conducting the initial nationwide test. Specifically, the rules required all communications
service providers that are required to participate in the national EAS also to participate in nationwide
testing of the EAS. In this regard, the FCC’s rules required EAS Participants to receive and, if required,
transmit the EAN and to submit test result data to the Commission within 45 days following the
nationwide test. On June 9, 2011, FEMA and the FCC announced that the first nationwide test would
take place on November 9, 2011 at 2:00 p.m. EST.19
From January 2011 through November 9, 2011, FEMA, the FCC and the EAS community conducted an
extensive outreach campaign directed at EAS Participants, state and local governments and consumers.
These efforts were designed to prepare EAS Participants for the test and to resolve technical and
operational issues as appropriate and to educate state and local governments, including 911 Call Centers,
and consumers about the test as well as the EAS in general. Examples of these activities included:
 FCC and FEMA-conducted webinars, roundtables and other meetings with EAS Participants to
discuss EAS best practices and FCC EAS requirements and to resolve outstanding technical and
operational issues, as needed;
 FCC and FEMA release of EAS test handbooks, an EAS Best Practices Guide, and toolkits designed
to educate EAS Participants about the nationwide test and how to prepare for it;
 FCC development of an electronic system to facilitate filing of EAS test result data by EAS
Participants;
 A joint FEMA-FCC letter to state governors as well as FCC and FEMA newsletter blurbs, webinars
and other activities directed at state and local government agencies regarding the Nationwide EAS
Test;
 FCC newsletter blurbs, emails to list serves, and/or meetings targeting consumer organizations,
including organizations representing people who do not speak English as well as groups representing
the deaf and hard of hearing and other disabilities;
 Joint FCC and FEMA meetings with organizations representing the deaf and hard of hearing to
address their concerns regarding the test;
 Production of video and audio FCC public service announcements (PSAs), in English and Spanish,
with open and closed captioning, regarding the nationwide EAS test;
 Voluntary dissemination of PSAs and production of other consumer outreach materials by the
National Association of Broadcasters, National Cable and Telecommunications Association and other
broadcast and cable industry participants for airing on local broadcast radio and television and cable
television systems;

18 Id.
19 Public Safety and Homeland Security Bureau Announces that First Ever Nationwide Diagnostic Test of the
Emergency Alert System will Occur on November 9, 2011 at 2 PM EST, EB Docket No. 04-296, Public Notice, 26
FCC Rcd 8398 (PSHSB 2011).
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 Voluntary airing of public service announcements (with open and/or closed captioning) by
approximately 100 national and regional broadcast and cable television networks immediately before
and/or after the Nationwide EAS test, alerting viewers that they were about to see or had seen the
nationwide EAS test;
 Voluntary development by EAS Participants and their industry organizations of an on-air slide that
indicated “This is ONLY A TEST.” This provided additional visual information to viewers;20 and
 FCC and FEMA consumer factsheets to provide basic information to consumers about the test. Both
agencies made these documents available on their respective websites and through the FCC
Consumer Call Center.
Because the test involved the first-ever simultaneous broadcast of a live EAS alert over most media-based
communications services nationwide, there was a potential for consumer confusion and panic. To
mitigate this concern, both FEMA and the FCC targeted significant outreach efforts to consumers and
worked with organizations such as the National Emergency Number Association and the Association of
Public Safety Communications Officials to educate 911 Call Centers about the test. These efforts proved
effective as neither FEMA nor the FCC received reports of increased calls to 911 as a result of the test.

IV. NATIONWIDE EAS TEST RESULTS

A.

Overview

The overwhelming majority of EAS Participants reported that they received the EAN. Broadcasters, the
largest segment of EAS Participants and the primary conduit for EAN distribution, reported widespread
successful propagation of the EAN nationwide, a result corroborated by cable operators and other EAS
Participants, who experienced similar success. That said, as discussed in more detail below, several
technical issues affected the distribution of the EAN system-wide, including difficulties arising from the
audio quality issues of FEMA’s transmission to the PEPs; failures at three PEP stations that resulted in
their inability to retransmit the EAN to other EAS Participants; and dependence by states that lacked a
PEP station or effective alternative means to receive the EAN, for example satellite-based options such as
the National Public Radio (NPR) “Squawk Channel”.21 Other EAS Participants experienced
individualized problems arising from equipment function, programming, user error, or the brevity of the
test message.

B.

Breakdown of Test Performance by EAS Participant Category

Table 1 provides an overview of the performance of EAS Participants according to their designation
within the EAS hierarchy. For purposes of this report, all cable operators fall into the Participating
National category.

20 Some EAS Participants noted that there would be some limitations in their ability to provide such backdrop visual
information. For example, a slide announcing “This is only a test” would not appear on some cable systems during
the test. Also, the test would be conducted only in English.
21 In addition to AM, FM, and broadcast radio stations, FEMA has designated Sirius XM Satellite, the Hawaii
Emergency Operations Center, and NPR as PEPs. With respect to NPR, from its Washington, D.C.-based Network
Operations Center, NPR distributes the EAN to public radio stations via the NPR Squawk Channel. Some State
EAS Plans designate the NPR Squawk Channel as an alternative monitoring source to the PEP from which EAS
Participants may receive an EAN. See n.31 infra. for an explanation of the NPR Squawk Channel.
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Federal Communications Commission

Table 1. EAS Participants’ Receipt of EAN based on EAS Designation22

EAS Designation

Stations

Receipt of EAN

Total

Broadcasters

%

Success

%

Failure

%

Stations

National Primary (PEP)23
6224
0.43%
59
95%
3
5%
State Primary
94
1%
79
84%
15
16%
State Relay
724
5%
606
84%
118
16%
Local Primary 1 (LP1 )
916
7%
756
83%
160
17%
Local Primary 2 (LP2 )
720
5%
580
81%
140
19%
Participating National
10,753
78%
9,026
84%
1,727
16%
Non-Participating
301
2%
219
73%
82
27%
National
Unidentified
217
2%
176
81%
41
19%

Total Broadcasters

13,787
11,501
83%
2,286
17%

Cable Operators

Headends

Participating National
2,94425
2,160
73%
784
27%

All Total


16,73126
13,661
82%
3,070
18%

22 Although the Commission received thousands of reports from EAS Participants, many entities did not submit the
required filings. The deadline for filing these reports was December 27, 2011. Since that time, the Bureau has
reached out, primarily through industry organizations including the National Association of Broadcasters, the
National Cable and Telecommunications Association, and the American Cable Association, to encourage those EAS
Participants that had not filed their mandatory reports to do so. As a result of this effort, PSHSB received numerous
additional filings in November 2012. However, there are a significant number of EAS Participants that still appear
not to have filed the required reports. Accordingly, the Bureau plans to confirm cases of continued non-filers and
refer them to the Enforcement Bureau for possible further action.
23 The National Primary numbers include three non-broadcaster PEPs: Sirius XM Satellite, the Hawaii Emergency
Operations Center, and NPR.
24 As noted earlier in this report, see note 2, supra, due to an ongoing severe weather storm in occurring in Alaska
during the test, the Alaska Department of Homeland Security requested that the EAN test not be broadcast in Alaska
so that the channels there could be used in the event that the EAS was needed to broadcast a local weather alert.
FEMA had anticipated that severe weather might affect actual test performance in certain areas and therefore
designed the test to accommodate the potential impact to the testing caused by Alaska’s absence from the test.
Although the Alaska PEP received and recorded the EAN from FEMA, they did not broadcast it and Alaska was
granted a waiver and was not required to file a report. Accordingly, Table 1, which is based on reports filed, shows
62 PEPs rather than the 63 that were in operation on November 11, 2011.
25 This category includes wireline video service providers in addition to traditional cable operators.
26 Under FCC rules, the Commission treats test result data submitted by EAS Participants as presumptively
confidential. Accordingly, for purposes of Table 1, we provide aggregated test result data to the extent doing so
does not result in disclosure of confidential information. As discussed in n.33, infra, we do not provide EAN receipt
data for two EAS Participants and do not include them among the 16,731 total number of filings. The omission of
this data does not change the assessment of the test in any significant way.
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Federal Communications Commission

1.

National Primary (PEP) Stations

At the time of the test, there were a total of 63 PEP stations in operation.27 According to FEMA, all 63
stations had a functioning connection to the FEMA-PEP conference bridge, which, as discussed above,28
connects the FEMA Operations Center to the PEP stations through the Public Switched Telephone
Network (PSTN) to enable simultaneous transmission of the EAN from FEMA to the PEPs.29 FEMA
reported that it successfully activated the EAN at 2:00 p.m. EST and transmitted the EAN to all 63 PEP
stations. According to FEMA, three of the PEP stations did not broadcast the EAN received from FEMA,
and the Alaska PEP received and recorded the EAN but did not broadcast as previously discussed.
According to FEMA, equipment at each of the non-Alaskan PEP stations (i.e., the stations that did not
plan to omit the broadcast element of the test) has been repaired or replaced and these PEP stations have
reported successful connection to FEMA during subsequent internal tests.
2.

Local Primary Stations (LPs)

The Commission’s rules require LP stations to monitor the PEPs for propagation of the EAN throughout
any given state. Many State EAS Plans30 also provide alternate sources for EAN monitoring by EAS
Participants, including the NPR Squawk Channel,31 which distributes the EAN to public radio stations via
satellite. In most State EAS Plans, LP stations serve as the primary source for disseminating the EAN
below the PEP level. LP stations are monitored by other EAS Participants, including broadcast, cable,
and satellite providers that the State EAS Plan does not otherwise designate with some other
characterization (such as LP). Most LP stations reported successful receipt of the EAN. Of
approximately 1,636 LP stations filing mandatory reports, 1,336, or 82%, reported successful receipt of
the EAN, while 300, or 18%, reported that they did not receive the EAN.

27 FEMA has made a major commitment to increasing the number of PEPs (and by extension the effectiveness of the
EAS) from the original 33 broadcast radio stations that comprised the PEP system to the 63 PEPs at the time of the
test. FEMA intends to increase this number to 77 by 2015, and thus cover over 90 percent of the US population
solely through the PEP system. See http://www.fema.gov/primary-entry-point-stations (last accessed March 28,
2013).
28 See section III.A, supra.
29 Unlike the rest of the EAS distribution architecture, which is primarily broadcast-based, the dissemination of the
EAN to the PEPs by FEMA is done over this PSTN link. FEMA has indicated that it is completing installation and
configuration of a satellite communications network to all PEP stations that will add a more capable and direct
communications channel to the PEPs while maintaining the terrestrial telephone network connectivity.
30 State EAS Plans describe procedures for state emergency management and other state officials, the National
Weather Service and EAS Participants’ personnel to transmit emergency information to the public during a state
EAS activation. Under the Commission’s rules, these plans should include information regarding monitoring
assignments and the specific primary and backup path for the EAN from the PEP station. State EAS Plans must be
reviewed and approved by the Chief, PSHSB. 47 C.F.R. § 11.21.
31 The NPR Squawk Channel is designed to deliver important news advisories and other timely information to
stations carrying NPR News. It allows producers to instantly communicate information (by voice) about upcoming
breaking news and live event coverage, including changes in program format and start and end times. See National
Public Radio, at http://www.npr.org/euonline/pub/squawk.htm.
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3.

Participating Nationals

Most EAS Participants are designated as Participating Nationals (PNs). The EAS Participants receive the
EAN from LP stations and broadcast it to the public. Of the 13,697 PNs that filed test reports, 82%
successfully received the EAN and delivered it to their customers.

C.

Performance by Classes of EAS Participant

1.

Broadcasters

Broadcasters constitute the largest group of EAS Participants. Of the 13,784 broadcast stations that
submitted test result data, approximately 83%, or 11,498 broadcasters, reported successful receipt of the
EAN.
2.

Cable Providers and Wireline Video Service Providers

Cable providers and wireline video service providers constitute the second largest EAS Participant group.
Cable service providers were required to file test data per headend, and each cable system may have
several cable headends.32 Of the 2,944 cable headends that filed test report data, approximately 73%
reported successful receipt of the EAN and 27% reported they did not receive the EAN.
3.

Satellite Systems

Test results varied among satellite system service providers, but in most cases, causes for any failure were
identical to those that affected broadcast and cable.33

V.

EQUIPMENT PERFORMANCE

Most EAS equipment functioned as designed, generating or receiving the EAN as required. Some EAS
equipment, however, performed in varying ways, due to differences in how manufacturers interpreted
rules in designing this equipment.34 During the test, most of this equipment functioned as designed,
generating or receiving the EAN as required. As a result, the test data revealed anomalies such as EAN
delay and inconsistent text crawl language.

VI. MOST SIGNIFICANT LESSONS LEARNED

The Nationwide EAS Test revealed a number of problems associated with EAS performance. Post-test
reports indicate that the problems fall into seven broad categories: poor audio quality; lack of a PEP
station, problems with the use of alternatives to the PEPs, inability to receive the EAN; inability to
retransmit the EAN (or deliver the EAN to the public); short test length; and issues associated with the
programming of EAS equipment. This section will discuss each of these problems.

32 A cable television headend is a master facility for receiving television signals for processing and distribution over
a cable television system.
33 This report does not include tabulated data on the performance of direct broadcast satellite service (DBS)
providers that participated in the test. Because there were only two such participants, the Bureau is concerned that
doing so could disclose confidential information.
34 See section VI.G, infra.
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Federal Communications Commission

A.

Widespread Poor Audio Quality Nationwide

As discussed earlier, FEMA reported that it transmitted the EAN to all 63 PEP stations.35 Many EAS
Participants noted widespread audio quality problems across the nationwide EAS hierarchy. FEMA
attributed this poor audio quality to “[a] technical malfunction [that] occurred at the National Primary
level that introduced a second set of EAN headers into the system. This affected the audio quality for
many downstream stations and in some cases, resulted in duplicated messages or muted the audio test
message.”36 FEMA has since informed the Bureau that it has taken the following actions to address this
problem:
 Correcting the FEMA PEP technical configurations to eliminate message duplication;
 Testing and deploying a two-way satellite network to improve connectivity and audio quality
between the FEMA Operations Center (FOC) and all PEP stations;
 Working with PEP EAS device manufacturers to correct potential technical anomalies that
may cause message repeat, attenuation and impedance issues;
 Working with its FOC and the telephone bridge manufacturer to upgrade the system to
prevent any accidental return and repeat of audio during an EAN event; and
 Continuing to test FEMA PEP network and equipment twice weekly.

B.

Lack of PEP Station

At the time of the test, FEMA had not established a PEP in Portland, Oregon.37 The Oregon EAS Plan
directed Oregon EAS Participants west of the Cascades, (in Portland, for example), to monitor KOPB-
FM, a Portland-based Public Broadcasting Service radio station that would receive the EAN from the
NPR Squawk Channel. According to press reports, the audio quality of the EAN that KOPB received
from FEMA via the NPR Squawk Channel was poor,38 and the station received a second set of EAN alert
tones within seconds after it received the initial EAN alert tones (caused by the feedback loop discussed
earlier). Further, equipment at the station rejected the Washington, D.C. location code that was used for
the test, and this terminated the alert partway through the transmission.39 Thus, most of the state’s EAS
Participants were unable to broadcast a complete EAN, and anyone listening for the alert heard only the
first few seconds of the test. FEMA has now expanded its PEP coverage in Oregon to include both
Eugene and Portland,40 and, according to personnel at Oregon Public Broadcasting, all equipment issues
have been resolved. Accordingly, any future EAN should propagate effectively throughout Oregon,
whether from a PEP or through the NPR Squawk Channel. Also, as we recommend below, the
Commission should initiate a proceeding to consider adoption of a national location code for any future
nationwide EAS test as well as for an actual national alert.

35 http://www.fema.gov/emergency-alert-system-eas (last accessed March 28, 2013).
36 Id.
37 See http://www.rwonline.com/article/walden-national-test-proved-eas-‘sort-of’-works/24851 (last accessed March
28, 2013).
38 See, e.g. http://www.kval.com/news/national/133545908.html ("Emergency Alert System Didn't Work in
Oregon") (last accessed March 28, 2013).
39 Id.
40 Oregon State Plan dated December 31, 2012.
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Federal Communications Commission

C.

Problems with the Use of Alternatives to PEP-Based EAN Distribution

During the run-up to the test, FEMA and PSHSB determined that there were some instances where EAS
Participants intended to use alternatives to the broadcast-based daisy chain architecture to receive the
EAN. Various test results and further discussions with FEMA have raised concerns that some of these
alternatives may not be able to receive the EAN effectively. PSHSB will continue to work with FEMA
and EAS stakeholders to examine this issue. In the meantime, we remind SECCs that state EAS plans
should specify where alternatives to the broadcast-based "daisy chain" architecture are being used and
that, as required by FCC rules, EAS Participants should seek FCC approval to use such alternatives.41
Further, state EAS plans should require that their state's PEP connection to the rest of EAS Participants be
tested on a regular basis.

D.

Inability to Receive the EAN

The vast majority of EAS Participants received the EAN from the stations they were assigned to monitor,
either at the PEP level or from stations located below the PEP level. For example, Texas broadcasters
informally reported that out of the 1,252 Texas radio and TV stations that participated in the Nationwide
EAS Test, only 22, less than 2 percent, failed to receive the EAN despite monitoring the sources required
by the EAS participant’s state EAS plan. There is no one cause for these failures, but to the extent that
EAS Participants were aware of reasons that they did not receive the EAN, reasons included user error
during the test, errors in programming equipment for the test, and mechanical anomalies related to the
test’s use of a Washington, D.C. location code.

E.

Inability to Retransmit the EAN and/or Deliver the Alert to the Public

Some EAS Participants reported that, although they were able to receive the EAN, they could not
broadcast it to viewers or listeners. In many cases, this was due to user error during the test or in
programming the equipment. Other EAS Participants or EAS Participant organizations reported that
some stations successfully received the EAN from both primary monitoring sources, but that the audio
portion of the EAN was so severely garbled that the equipment could not retransmit it to other EAS
Participants for broadcast to the public, and that the EAN from the NPR Squawk Channel contained
duplicate EAN tones that may have triggered the EAS equipment to terminate the alert.

F.

Short Test Length

Two EAS Participants reported an inability to deliver the EAN to the public due to the short 30-second
duration of the test. One EAS Participant reported that its EAS equipment cannot rebroadcast an EAN
shorter than 75 seconds. As a result, while it apparently received the EAN, it could not retransmit it to
subscribers. Another EAS Participant suggested that the 30-second duration of the test was insufficient to
allow its engineers to manually override its equipment when automatic equipment functions failed.

G.

Anomalies in EAS Equipment Programming and Operation

In designing and/or programming EAS equipment, manufacturers have made certain inconsistent
assumptions about the requirements of the EAS rules. As a result, alerting information was not processed
or retransmitted in a uniform manner throughout the EAS system, which caused certain problems. For
example, several EAS Participants reported that there was a three minute delay in their rebroadcast of the
EAN.

41 See 47 CFR § 11.52(d)(4).
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Federal Communications Commission

On December 15, 2011, Monroe Electronics, an EAS equipment manufacturer, filed an ex parte letter
stating that its equipment initiated EAN transmission at 2:03 p.m. (rather than at the scheduled time of
2:00 p.m.) because the EAN’s header “time of transmission” code was set for 2:03 p.m. In designing its
equipment Monroe Electronics interpreted the Commission’s EAS rules to require that it follow each code
element in the EAS header.42 Other manufacturers’ equipment is programmed to override the “time of
transmission code” when an EAN is received. Monroe raised the issue of whether the EAS rules should
require EAS equipment to automatically synchronize receipt of EAS alerts with their dissemination, so
that the EAS Participant would disseminate an EAS alert at the same time it is received.43
As indicated in section VI.B and VI.D above, another example arising from equipment programming was
the use of the Washington, D.C. location code, which caused some equipment to reject the alert. Other
EAS equipment was programmed to ignore a location code when an EAN was received, in which case the
alert went through. As a third example, the language in the text crawl that EAS equipment generates from
the EAN differs among manufacturers, and many EAS Participants’ equipment generated a text crawl that
went by too quickly or was in a difficult to read font.
As explained below, the Bureau recommends that the Commission initiate a proceeding to consider these
types of equipment performance issues.

VII. A PATH FORWARD TO STRENGTHENING THE EAS

Based on our review of test result information as well as discussions with FEMA, EAS Participants and
equipment manufacturers, PSHSB makes several recommendations for the Commission’s consideration
to address the specific lessons learned identified above. In addition the Bureau recommends several next
steps in preparation for future nationwide EAS tests. The Bureau believes that implementation of all of
these recommendations will help improve the EAS and ensure that this alerting system serves as a reliable
tool to enable the President, as well as state and local governments, to send timely and accurate
emergency alerts to the American public.

A.

Specific Recommendations To Address Significant Problems Identified By the
Nationwide EAS Test

1.
Equipment Performance
The Commission should consider commencing a proceeding to examine equipment performance issues
during activation of an EAN and to seek comment on proposed changes, if any, to the EAS equipment
rules to ensure that all EAS equipment operates in a mutually consistent fashion. As noted above, the test
revealed that equipment manufacturers have followed inconsistent interpretations of the Commission’s
rules in designing and/or programming their products. For example, the manner in which one equipment
manufacturer applied the FCC’s rules for following EAN code elements resulted in a three minute
retransmission delay of the EAN. Further, EAN text crawl language is not consistent among
manufacturers, as each ascribes different language to the EAS code for video display purposes. The
Bureau believes that all equipment should receive and transmit the EAN (as well as all other EAS alerts)
to the public in a consistent manner. These issues are best addressed in the context of a formal
proceeding.

42 Monroe Electronics, Letter from James F. Heminway, Chief Operating Officer, Monroe Electronics, to Adm.
Jamie Barnett, Chief, Public Safety and Homeland Security Bureau, FCC, Dec. 15, 2011 (Monroe Ex Parte).
43 Id.
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Federal Communications Commission

2.
State EAS Plans
a.
Need to Update State EAS Plans
The test revealed some indications that the state EAS plans may be insufficiently clear. For example,
several EAS Participants reported difficulties in understanding their monitoring assignments as set forth
under their state’s EAS plan. Accordingly, the Bureau recommends that the Commission should consider
issuing a Public Notice encouraging SECCs to review and update their EAS plans, as necessary, to ensure
they contain accurate and up-to-date information regarding monitoring assignments as required by FCC
rules.
b.
Re-examination of FCC’s State EAS Plan Rules
The Bureau recommends that the Commission should also consider reviewing its State EAS Plan rules
and seek comment on proposed changes, as necessary. It became clear in the run up to the test and in the
Bureau’s and FEMA’s post-test analysis, that state EAS plans do not require EAS participants to provide
data below the LP level, resulting in a failure to provide sufficiently detailed information regarding the
propagation of a national (or any other) EAS alert as contemplated by the FCC’s rules. Further, as the
Commission noted in its EAS Fifth Report and Order, some stakeholders have noted that the
Commission’s rules do not establish adequate guidelines for the structure of state EAS plans,44 and fail to
define the role for SECCs or the procedures by which SECC members are selected. The need for this
became evident during post-test analysis, where the lack of consistency among plans made it very
difficult for the Commission and FEMA to create a national propagation map. Finally, as of June 30,
2012, EAS Participants were required to have the capability to receive and process EAS alerts formatted
in the Common Alerting Protocol (CAP),45 as delivered over FEMA’s Integrated Public Alert and
Warning System (IPAWS). As a result, SECCs were required to amend state EAS plans to include this
new Internet-based monitoring obligation. Although EAS Participants are not required to receive state
EAS alerts, CAP-based or otherwise, the time is ripe for the Commission to consider what, if any,
changes to its rules regarding state EAS plans are necessary in light of the introduction to CAP-based
EAS. In addition, the Commission should also consider whether to make the state EAS plan process into
an online, rather than a paper filing, process.
3.
Develop and Publicize EAS Participant Best Practices for EAS Operation
Prior to and during the test, both the Bureau and FEMA found that many EAS Participants had many
questions about the operation of their EAS equipment and their conduct during the test. To address these
questions, the Commission drafted a “day of” Nationwide EAS Handbook for EAS Participants to give
them a step by step operational and instructional guide for what to do during the test. FEMA issued an
EAS Best Practices Guide and toolkits to educate EAS Participants about EAS operation, particularly
during EAN activation. We believe such efforts are quite valuable in educating EAS Participants about
the EAS and, accordingly, recommend that the FCC and FEMA work together to determine other areas

44 See Fifth Report and Order, 27 FCC Rcd at 734, ¶ 27.
45 CAP is an open, interoperable XML-based standard that allows an alert initiator to deliver information-rich alerts
to multiple devices. See Fifth Report and Order, 27 FCC Rcd at 648 ¶ 10. FEMA’s IPAWS is a modernization and
integration of the nation’s alert and warning infrastructure. See FEMA, “Integrated Public Alert and Warning
System,” available at http://www.fema.gov/integrated-public-alert-warning-system (last accessed April 8, 2013).
The November 11, 2011 Nationwide EAS Test was solely a test of the broadcast-based “daisy chain” distribution
architecture discussed in section III.A., and did not test IPAWS or CAP.
17

Federal Communications Commission

where issuance of joint best practices and other educational materials may be beneficial to EAS
Participants and to work together to issue such materials within the next year. Along the same lines,
PSHSB recommends that it and FEMA conduct a joint roundtable, webinar or other public workshop
designed to provide opportunities to educate EAS Participants about EAS performance and to address
concerns and questions EAS Participants may have about EAN operations.

B.

Next Steps For the Next Nationwide EAS Test

The Commission’s rules and orders contemplate additional nationwide EAS tests. Although the next test
has not yet been scheduled, the FCC, FEMA and other EAS stakeholders need to take a number of steps
now for that event. Along these lines, the Bureau makes the following recommendations for actions that
should be taken in advance of the next test.
1.
Need for Additional FCC Rulemakings
The Commission should commence a proceeding to address operational nationwide EAS test issues left
open in previous EAS orders. In both the Third Report and Order and the Fifth Report and Order in the
EAS proceeding,46 the Commission deferred action on or delegated authority to PSHSB to decide a
number of issues (and implement the decisions) concerning the initial nationwide EAS test, such as
whether the Commission should adopt a national location code, whether, for future tests, the National
Periodic Test (NPT) code should be used in lieu of the live EAN code, and whether EAS Participants
should continue to use an EAS Operations Handbook. The Bureau used this authority to make a number
of decisions regarding the conduct of the first nationwide EAS test, such as using the Washington, D.C.
location code in lieu of a national location code. In light of post-test analysis and discussions with FEMA
and EAS stakeholders about these issues, the Bureau believes that many of these issues call for a
permanent, rather than ad hoc, resolution, and so should be addressed in a formal notice and comment
rulemaking in which all stakeholders may have an opportunity to provide input. Moreover, in some
cases, FEMA has recommended that the Commission consider rule changes to address these issues. For
example, to bring more consistency to the way EAS equipment processes the EAN, FEMA has
recommended that the Commission consider adopting a national location code that could be used for both
actual and test activations of the EAN. FEMA has also recommended that the Commission consider
changes to its rules regarding the NPT code so that it serves as a viable and less burdensome alternative to
use of the EAN.47
The Bureau recommends that the Commission commence a rulemaking proceeding to consider and
resolve these operational issues. This approach is an efficient way to engage all stakeholders in
discussing and crafting solutions to these issues. In conjunction with this proceeding, the Commission
should also consider hosting at least one roundtable meeting and/or a public workshop to discuss these
issues with EAS stakeholders.

46 See, e.g., Third Report and Order, 26 FCC Rcd at 1470, 1474, ¶¶ 25, 32; Fifth Report and Order, 27 FCC Rcd at
716, ¶ 210.
47 Use of the NPT would allow FEMA and the FCC to conduct nationwide EAS testing without the need for an
extensive public outreach campaign such as that necessary for the first nationwide EAS test. The rules as currently
written, however, do not allow the NPT to perform in the same manner as the EAN and therefore, use of the NPT for
the November 9, 2011 test would not have allowed FEMA and the FCC to assess whether the system works as
designed.
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Federal Communications Commission

2.
Develop a New EAS Test Database
For the first nationwide EAS test, PSHSB launched a Nationwide EAS Test Reporting System that
allowed EAS Participants, if they chose, to file test result data electronically. EAS Participants that filed
in this manner were asked to submit three reports at the following intervals: (1) Form 1 - Background
Information to be voluntarily submitted prior to November 9, 2011; (2) Form 2 Day of Test Results to be
voluntarily submitted only on November 9, 2011; and (3) Final Mandatory Report, requiring the
combined information requested in Form 1 and Form 2, as well as an explanation of system performance,
to be submitted by December 27, 2011. PSHSB made this system available for electronic filing on its
website through January 13, 2012, at which time the database platform underlying the reporting system
was decommissioned because the FCC transitioned to a new database platform. For this reason, the
Commission should consider creating a new electronic filing system to facilitate electronic filing of test
result data for any future nationwide EAS test. As noted above, the date of the next test has not yet been
scheduled. Nonetheless, since the FCC’s rules and orders contemplate future nationwide testing, it would
be consistent with that planning for the Commission to consider starting the development of a new
database now.
As a first step, the Bureau should host roundtable discussions with various EAS Participants as well as
members of the communications bar to receive feedback on the strengths and weaknesses of the previous
system. The Bureau can then use this feedback to develop a system that efficiently allows EAS
Participants to file test results and allows the FCC staff to analyze the information it receives.
The Bureau recommends that any new database be made available to EAS Participants at least two
months in advance of the next nationwide EAS test. This should give EAS Participants time to become
familiar with the new database and for the FCC staff to address any problems well in advance of the test.
3.
Reconvene the Federal EAS Test Working Group
PSHSB recommends that the Commission consider requesting the EOP to reconvene the Federal EAS
Test Working Group to address issues raised in the first test and to plan the next nationwide EAS test. As
noted above, the working group, consisting of FCC, FEMA, NOAA and other federal agencies, regularly
coordinated every facet of the first nationwide test. In addition, EOP oversight ensured accountability
throughout the process leading up to the test. The Bureau believes this model should be followed for
future tests.
As a subset of this recommendation, PSHSB recommends that it and FEMA should continue to meet,
both formally and informally, on a regular basis to exchange information and to work together to address
problems identified by the test. Meetings among PSHSB and IPAWS staff should occur at least once a
month while meetings between the Chief of the PSHSB and the Assistant Administrator for National
Continuity Programs should continue at least once every quarter with the option to meet more frequently
as needed.

VIII. CONCLUSION

The first-ever Nationwide EAS Test was a success in that it demonstrated that the national EAS would
generally perform as designed, if activated. At the same time, the test shined a bright light on several
areas – systemic and local – requiring improvement. The Bureau will continue to work with FEMA, EAS
Participants and other EAS stakeholders to address these problems and to ensure that the EAS can deliver
timely and accurate national alerts to the public, if and when needed.
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