Working Group #9CAP Implementation

March 22, 2012

Co-Chair Chris HomerCo-Chair Ed Czarnecki

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Working Group #: Name

Description: The immediate focus for Working Group 9 is to review the Fifth Report & Order (released January 10, 2012) on CAP deployment, provide recommendations and best practices to the FCC and CAP implementation progress through 2012.

Duration: First Report March 2012 Second Report December 2012

D = draft report to Steering Committee F = final report to CSRIC Members V = Vote by full CSRIC

Sept. 2011

Oct. 2011

Nov. 2011

Dec. 2011

Jan. 2012

Feb. 2012

Mar. 2012

Apr. 2012

May 2012

June 2012

July 2012

Aug. 2012

Sept. 2012

Oct. 2012

Nov. 2012

Dec. 2012

Jan. 2013

Feb. 2013

Mar. 2013

Working Group 1

Working Group 2

Working Group 3

Working Group 4

Working Group 5

Working Group 6

Working Group 8

Working Group 9

Working Group 10

Working Group 7

V = TBD

Deliverab

les: D=

2/6/13, F=

2/20/13, V =

3/6/13

Deliverab

les: D=

8/15/12, F=

8/29/12, V =

9/12/12

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les: D=

11/7/12, F=

11/21/12, V =

12/5/12

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2/23/12, F=

3/8/12, V =

3/22/12

Deliverab

le s: D=

5/9/12, F=

5/23/12, V =

6/6/12

D = 12/5/11F= 12/5/11V = 12/8/11

Working Group Deliverable Timeline

Working Group 9 –Participants Alfred Kenyon FEMA Andy Scott, National Cable

Television Association (NCTA) Bill Marriott, ComLabs Bill Robertson, DAS Bob Sherry, Intrado Chris Homer, DirecTV (Chair) Clay Freinwald, Washington SECC Daryl Parker, TFT Donald Walker, GRM Edward Czarnecki, Monroe

Electronics (Co-Chair) Gary Timm, Wisconsin SECC Harold Price, Sage Alerting Systems

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Jeb Benedict, CenturyLink Jeff Staigh, Univision Jim Gorman Gorman-Redlich Kelly Williams, National

Association of Broadcasters (NAB)

Larry Estlack, Michigan Association of Broadcasters

Matt Straeb, GSS Michael Hooker, T-Mobile Mike Nawrocki, Verizon Ron Boyer, Time Warner Cable Tim Dunn, T-Mobile Eric Ehrenreich, FCC

Working Group 9 - Executive Summary

The Emergency Alert System is the primary warning system that provides the President with the means to address the nation during a national crisis. – On May 31, 2007, the FCC adopted a Second Report & Order to

require EAS participants to accept messages using CAP digital delivery.– On January 10, 2012 the FCC released the Fifth Report and Order

which further clarified the process to receive and transmit CAP messages for the EAS, and to streamline the Part 11 rules.

A specific area of investigation by WG9 pertains to the impact of the FCC’s Fifth Report and Order on EAS (released 10 January 2012) on CAP EAS migration.

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Working Group # 9 - Findings The FCC Fifth Report and Order disallows the use of text-to-speech

conversion technology on and CAP EAS device (at least pending a future proceeding). It does concede the potential use of such technology by CAP originators

themselves. We observe that several CAP-based EAS origination and relay systems,

including FEMA IPAWS, rely on the use of Text to Speech technology. It was noted that the National Weather Service is preparing to feed CAP to

IPAWS by April 2012, but also will rely on use of Text to Speech. Furthermore, at least one deployed and operational CAP relay system is

similarly predicated on the use of text to speech by EAS devices. We noted that the absence of Text to Speech technology could compromise

alert message usability, if it was not available as a backup capability if an audio file was absent or unusable.

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Working Group # 9 - Findings

EAS Device Certification The working group examined the revised CAP EAS device certification

process in depth. Three classes of CAP equipment were created by the Commission: Integrated CAP EAS encoder/decodersUniversal intermediary devices Component intermediary devices

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Working Group # 9 - Findings

Implications of “Streamlined” Process for Integrated CAP EAS devices Subcommittee consensus that the report and order indicates that

integrated CAP EAS devices are required to submit a class II permissive change filing, plus a copy of an SDoC.

The consensus among subcommittee members was that universal intermediary devices holding a valid SDoC had a reasonable possibility of meeting the Part 11 certification requirements by 30 June 2012, provided that the Part 11 testing regime was “on line” at the earliest possible time.

The consensus among subcommittee members was that universal intermediary devices that hold neither a valid SDoC nor Part 11 certification, may face challenges in meeting the certification requirements by 30 June 2012, given the remaining timeline.

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Working Group # 9 - Findings

Potential issues of combining IPAWS Conformity Assessment with FCC Part 11 Equipment Certification Among other issues, the FEMA CAP conformity test guidance –

needed for test facilities to review and design of their test support programs - has not yet been publicly posted.

Nonetheless, completion of Part 11 testing of products with an existing valid SDoC/Test Report is feasible by June 30, 2012.

There was broad consensus that this situation does not warrant any extension to the 30 June 2012 CAP compliance deadline.

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Working Group # 9 - Recommendations

Text to Speech WG-9 recommends “Text to Speech” Prohibition be removed for the following reasons; At a minimum, it would enhance alert message usability as a backup, in

the event that an audio file was absent or unusable. It would increase the overall success of CAP rollout for participants

based on current findings. It would allow a more diverse group of providers to participate. It would reduce operational costs for alert originators, in terms of total

bandwidth required by CAP Originators, CAP disseminators, and EAS Participants

It would prevent unplanned costs for Originators (typically State, Local, Tribal and Territorial government agencies), who would have to either acquire or alter their existing systems to originate high quality audio.

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Working Group # 9 - Recommendations

WG-9 recommends that the FCC incorporate the EAS-CAP Industry Group Implementations Guidelines on “Text to Speech” Provides for the ability to process an audio file in a specified

format for EAS voice. Provides for text to speech conversion in the event, for whatever

reason, that audio file is unavailable or unusable.

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Working Group # 9 - RecommendationsDevice certification

Recommend that contents of paragraphs 170 and 171 in the Fifth Report & Order be incorporated into the amendments of Part 11.

Recommend that FCC require submission of BOTH a vendor supplied SDoC and third party CAP Conformance Test Report (i.e. IPAWS CA or TCB).

Recommend that all testing under the streamlined certification process be conducted in accordance with §11.34, and Certified in accordance with the procedures in Part 2, Subpart J (47 CFR 2), via an FCC-approved facility.

Recommend that any other self-certification be disallowed, as being inconsistent with the procedures set forth in Part 2, Subpart J.

Recommend that FCC testing ensure certifications relate to the specific product combination (hardware model + software version) that was actually tested.

Recommend that that FEMA issue its CAP conformity test guidance as quickly as possible, so that prospective laboratories may begin review and design of their test support programs.

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Working Group # 9 - Recommendations

WG-9 recommends that the 30 June 2012 deadline remain in place.

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Working Group # 9 – Best Practices If the “Text to Speech” prohibition remains in effect

EAS participants should confirm with their respective equipment vendors to ensure system firmware/software versions are up to date and the text to speech option is disabled.

EAS CAP equipment manufacturers should provide guidance to EAS Participants, as soon as practical, as to how the text to speech option can be disabled on each respective version of equipment.

Federal agencies (FCC and FEMA) should develop additional specific best practices and guidance for by (a) CAP EAS alert origination systems (b) users of such equipment (state, county, local, tribal and territorial) on making audio files (mp3) available locally.

Local Government and CAP system developers: If audio files on remote servers are to be relied on as the source for EAS audio, then developers should consider how that audio can reside in a trusted environment where the content would not be compromised before, during or after an alert event.

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Working Group # 9 – Best Practices If the “Text to Speech” prohibition is rescinded

EAS participants: Should work with their respective manufacturers to identify and wherever possible remediate any significant inconsistencies or errors in pronunciation, etc.

EAS CAP equipment manufacturers: Should voluntarily and proactively respond to any significant inconsistencies, errors in pronunciation, or local lexicon.

Local Government and CAP system developers: Should follow best practices, for example as contained in FEMA training course IS-247, to ensure as much as possible that the CAP text message being delivered should not contain jargon, acronyms, and letter/number.

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Working Group # 9 – Best Practices CAP EAS Equipment Certification

EAS Participants: Should coordinate with their respective equipment manufacturers on the process under which their equipment will meet the required streamlined certification process.

Equipment Manufacturers: Should take early steps to prepare for their requirements under the streamlined certification process, so that they provide themselves and customers with the least level of risk.

FCC: Should ensure that equipment certifications relate to the specific product combination (hardware model + software version) that was actually tested.

FCC and FEMA: Should coordinate closely on preparation of facilities supporting the streamlined certification process.

FEMA should issue the CAP conformity test guidance as quickly as possible, so that test facilities may review and design their test support programs.

The FCC should continue the use of certified third-party test facilities for both Part 11 and CAP conformance testing (per 47 CFR Part 2, Subpart J).

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Working Group # 9 - Next Steps

Monitor progress of CAP Implementation National Level State Level Local

Track Issues Topology Capacity/Availability Security Reliability

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2012

WG9 Report - TBA: 12/16/11

CSRIC MeetingFriday, 12/16/2011

AprFebJanDecNov Mar

Final CSRIC MeetingWednesday, March 6, 2013

CSRIC MeetingThurs, 3/8/2012B/P Target Date

CSRIC MeetingWeds, 6/6/2012

FCC CAP Deadline6/30/2012

CSRIC MeetingWeds, 9/12/2012

OctAugJulJunMay Sep JanDecNov

WG9 Implementation Report: 12/5/12

CSRIC MeetingFriday, 12/5/2012

2013

Tentative - Project Timeline

WG9 KickoffMeeting