When finalizing rules about EAS this winter, the FCC deferred action on one involving text-to-speech software in CAP receivers.

The decision occupied only a paragraph within a 130-page document, yet it prompted a strong, unusually unified response from the manufacturing community, FEMA and others who say the commission is making a dangerous mistake.

The full order stipulates how stations and other participants receive alert messages formatted in the Common Alerting Protocol. (Among other outcomes, the FCC dropped a proposed requirement that stations must accommodate messages from state governors, the so-called “governor’s must carry” provision.) Stations need to meet various CAP requirements by June 30, as we have reported.

But the FCC deferred action on text-to-speech for a future proceeding, and blocked use of such software in the meantime. It cited concerns about the accuracy and reliability of the technology.

In doing so it went against advice from the EAS-CAP Industry Group, whose recommendations have played a key role in FCC EAS implementation. The group had said that in the absence of attached audio files, EAS devices that handle text-to-speech should be allowed to create the audio portion of alerts by constructing audio from the CAP messages.

The FCC demurred, saying that performing text-to-speech conversion in EAS equipment software, as opposed to software an alert message originator might employ, “could result in differing audio messages being broadcast for the same EAS message, depending upon which software brand and version a given equipment manufacturer elected to incorporate into its EAS equipment.”

No backup

Numerous suppliers of EAS gear and services have asked the FCC to reconsider. They include Sage Alerting Systems, iBiquity Digital, TFT, Monroe Electronics/Digital Alert Systems, Alerting Solutions Inc., MyStateUSA, Communications Laboratories Inc. (Comlabs) and Warning Systems Inc.

These are members of the ECIG and are involved in EAS in varied ways; some are fierce competitors. But they told the FCC that their feelings “represent a consensus.”

They warned of “very significant and potentially adverse implications” that would result by a ban on text-to-speech. The impact on EAS participants and originators, they wrote, may be “profound,” removing important backup capability where an audio file from an originator might be missing or damaged. Broadcast radio listeners might hear only header tones, Attention Signal3 and EOM tones.

“Listeners may know that there is an emergency situation … but they will have no information about the nature of the emergency,” they wrote. “The potential for widespread confusion and/or disregard for the EAS could be the result.” Visual media could have audio components impaired.

Further, CAP EAS originators including FEMA may be affected, because the IPAWS system uses text-to-speech translation at the CAP receiver. The National Weather Service CAP feed also relies on text to speech. “Apparently NWS may not necessarily and consistently create audio files for download construction of EAS protocol messages by these devices.”

And the FCC decision could hurt state aggregator and distribution systems in place or underway. Dissemination systems might need changes that would cost agencies money that isn’t available. There could also be unforeseen consequences for people with disabilities.

Unintended consequences

Almost simultaneously with their comments, FEMA itself petitioned the FCC to reconsider.

The agency — which administers EAS, developed the Integrated Public Alert and Warning System profile and operates a CAP message aggregator — warned of unintended consequences that could “severely limit” what local emergency management officials can do with CAP.

Antwane Johnson, division director of IPAWS, wrote that the FCC apparently had relied on comments from Sage in support of a marketplace approach to text-to-speech conversion; but he said the FCC action actually precludes marketplace activity and discourages further development of the technology for EAS.

Also, contrary to what the FCC said, he could find no evidence of concerns about the accuracy and reliability of text-to-speech software. And if this prohibition stands, Washington state and at least two other states would have to “stop using this active, tested method of alerting the public.” He listed other complications and scenarios too. (I’ve posted links to his succinct comments as well as those from ECIG at radioworld.com/Apr-11-2012.)

In short, FEMA said, the FCC should stick with the original ECIG recommendations. Alert originators then could provide audio message files if they desire.

‘Severe’ impact

In late March, RW reported on our website that an FCC advisory committee had added their voice. The Communications, Security, Reliability and Interoperability Council recommended that the FCC reverse the ban.

Alerting company Global Security Systems also did so, saying the decision would have “severe impact” on the usefulness of alerts. It repeated arguments that the exemption would force stations, originators and the interconnecting IP relay networks to seek more bandwidth, which may not be possible and could “deter the success of the entire process.”

Several state and local emergency management agencies have filed comments supporting FEMA and ECIG, and I’m told that Nebraska state emergency planners think they will have to put its state CAP project on hold until a solution is found.

One source told me: “Over half of the states already have a CAP system deployed or under contract, and there is unanimous consensus among all of the providers of these systems that the text-to-speech prohibition should be rescinded.”

In early April, the Broadcast Warning Working Group issued its own strong support of the FEMA request. “Launching CAP-EAS on June 30 of this year, while at the same time prohibiting the key CAP-EAS benefit of TTS, makes no sense, and will have the effect of damaging the emerging CAP-EAS IPAWS OPEN ‘brand’ in the eyes of the public,” wrote the group, which consists of people involved in various aspects of EAS.

BWWG said Washington state’s experience shows that text-to-speech is up to the job and that adjustments to difficult word pronunciations are possible. If the system can support specific pronunciations of words like Skokomish and Snoqulamie as it does in Washington, the group argued, TTS implementation can be made to work. It explored other complications as well. Its comments, too, are at the links page I cited earlier.

Rarely have so many voices in the EAS community spoken in near-unison. I believe the FCC will overturn the text-to-speech prohibition. I imagine this might happen quickly.

This is but one angle of the ongoing EAS story (details of product certification are another). It’s interesting to watch how it plays out.

Overall, though, the June 30 CAP compliance deadline stands. Unsure if your station is in compliance? Ask your station counsel or EAS equipment supplier.