“This Is Only A(nother) Test …”

In connection with second-ever nationwide EAS test (now scheduled for September), FCC introduces new EAS Test Reporting System

If you participate in the Emergency Alert System, it's time to get out your calendars and circle Wednesday, September 28, 2016 - because we now know that that's the day on which our friends at the Federal Emergency Management Agency (FEMA) are planning on conducting the second-ever nationwide test of the EAS. We don't know the time of day yet or a number of other details that will certainly come into play, but at least the date has been announced.

And in connection with that test, the Commission wants you to know that it's putting the finishing touches on its brand new EAS Test Reporting System (ETRS). That system was first previewed last June, when the Commission adopted a number of revisions to the EAS. But at that point ETRS was more a theoretical concept than an actual set of forms. No more. ETRS has moved from the conceptual here's-what-we're-thinking-about stage to the drafted-and-almost-ready-for-prime-time stage.

In an announcement previewing the system, the Commission has provided a walk-through of the ETRS, complete with screen grabs of the draft online form (and it's nice to have those grabs, because the online site isn't available yet to walk through). All EAS participants should be sure to take a gander at the FCC's public notice, because submitting the three separate tiers of the ETRS reports will be mandatory.

Before we get to the nitty-gritty, a quick refresher might help.

A primary purpose of the EAS (like its precursors, the Emergency Broadcasting System (1963-1997) and Conelrad (1951-1963)) is to afford the President the ability to notify the entire U.S. population, simultaneously, of nationwide emergencies. Since its establishment, of course, the EAS has also been used - very effectively - to permit regional, state and local officials to warn folks of regional, state-wide or local emergencies like weather conditions, hazardous circumstances (e.g., train derailments possibly releasing harmful substances), and the like.

But whether or not the system would actually work on a nationwide level had never been tested prior to 2011.

In November, 2011, after a considerable amount of preparation, the first nationwide EAS test was performed. To assess the system's performance, the Commission devised a three-step reporting process. Step one required EAS participants to identify themselves (name, facility ID number, transmitter coordinates, nature of EAS participation, etc.). Step Two required all participants to report to the FCC, within 24 hours of the nationwide test, whether they had received and retransmitted the EAS alert. And Step Three was a follow-up report seeking more detail about any problems that any participant may have encountered in the test process.

The 2011 test turned up a few problems with the EAS which the FCC then set about correcting. Last June it revised a number of the EAS's technical provisions.

By then, the Commission had concluded that the approach it had taken to follow-up reporting in 2011 was the way to go for future tests. But, in lieu of the somewhat ad hoc forms used in 2011 (which included the option of using either a hard-copy or an online version), the FCC decided that a more sophisticated, totally electronic system should be used to (a) facilitate the process for EAS participants and (b) make the collected data more useful to the Commission.

Which brings us to ETRS.

Unlike the 2011 system, and seemingly contrary to the Commission's ongoing efforts to consolidate electronic filing functions, ETRS has been given a separate status that requires participants to set up their own separate ETRS accounts. To access an ETRS account, a reporting participant will need its own ETRS username and ETRS password. And it appears that those will be assigned by the ETRS registration system.

To get the registration process started, an EAS participant will have to go to the ETRS registration form, which will be somewhere on the FCC's website. (Where exactly? We can't say for sure just now: The Commission hasn't announced the URL, but plans to do so in a "forthcoming public notice".) Once you're at the registration page, you'll need to enter the following information:

• your name;
• your contact information;
• the legal name of the EAS participant for which you are filing;
• the EAS participant's FRN and the password associated with that FRN.

With that, the FCC will email you your ETRS username, an ETRS password, and instructions for accessing ETRS. And that's what you'll need to get in the door to complete the mandatory report. (As with any password, be sure to keep it in a safe place where you'll know where to find it.)

As in 2011, EAS participants will be required to file three separate components:

"Form One - Identifying and Background Information". This will have to be filed within 60 days of the "official launch" of ETRS; the Commission will be letting us know that date when the time comes.

As the name indicates, here's where you'll have to provide detailed information about the station(s) that will be reporting, their transmitter location(s), EAS assignments and related equipment, etc., etc. Because the ETRS will be linked to other Commission databases, when you enter a station's call sign, its facility ID number and transmitter coordinates should prepopulate. (But heads up: the ETRS requires coordinates in NAD83, not NAD27. This is important because CDBS generally uses NAD27, unlike virtually all other FCC databases. That being the case, it would probably be prudent to doublecheck the numbers ETRS pops into the coordinates box, just to be sure.)

You'll also need to provide contact information for the person completing the form. That particular set of questions will prepopulate with the information provided during the initial registration process; if the person filing the form will be different from the one who took care of the registration, you'll be able to change that. Additionally, you'll need to provide separate contact info for the person who will serve as the "emergency contact" during any nationwide test (if that person is different from the normal contact person).

Of course, when any of this information changes, you'll have to log on and upload the changes.

"Form Two - Day of Test Reporting". This form will have to be submitted within 24 hours of any nationwide EAS test (or as the Commission may otherwise specify). Much of the information (reporting entity, contact information, etc.) should prepopulate from the registration information. The two new questions here are simple yes/no items: did the station receive the EAS alert, and did the station retransmit the EAS alert. (Before you log out you'll also be required to confirm the accuracy of the contact information on file.)

"Form Three - Detailed Test Reporting". This form, due to be filed within 45 days of the nationwide EAS test, calls for a more granular report about what happened during the test. In addition to prepopulated items, the form asks whether: (a) the alert was received and, if so, from what source, when, and whether there were any complications; and (b) the alert was retransmitted and, if so, when and, again, whether there were complications. The Commission helpfully provides drop-down menus of generic types of complications, plus a box in which details of any complications can be provided. (Of course, "no complications" is also an option.)

All submissions will have to be certified by the responding participant under penalty of perjury.

There are other bells and whistles involved in the system - batch filing capability, "feature tabs" on the interface, etc. - but for now, at least, we just want to make sure that all EAS participants have an idea of what they can expect to deal with in the next five months or so. Check back here for updates.