The State of Technology (SoT) Project of the Wireless RERC filed comments on February 18, 2010, in the FCC’s Second Further Notice of Proposed In the Matter of Review of the Emergency Alert System [EB Docket No. 04-296]. The FCC sought comment on revising Part 11 rules governing EAS to allow for periodic testing of EAS on a national scale. Though EAS was created to be a national alerting system, providing the president the capability to reach all US citizens simultaneously, it has never been used as such. Comments support the FCC’s efforts to revise the rules to explicitly require periodic nationwide testing, but emphasized that consideration of people with disabilities in all aspect of EAS, including testing, is necessary. Specifically, comments expressed concerns that EAS participants that are required to transmit both the audio and visual components of an EAN message, only have to transmit certain elements in the digital header portion of the EAN message visually. Persons who are deaf or hard of hearing will only see certain message elements and not hear the audio that this is a test. Comments suggested that those EAS participants that transmit video be required to transmit an open caption stating that this is a test. Other items addressed were reporting requirements of the nationwide test results and vulnerabilities to the system, especially how the alerts are made accessible to people with disabilities.
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