Statement of Michelle Bradley: Report of the 2018 National EAS Test and LPFM

Today, the Federal Communications Commission Public Safety and Homeland Security Bureau released the Report of the 2018 National EAS Test.  Here are some of the bullet points from that test:

• This year's EAS test was different as it was tainted by political rhetoric surrounding the the fact that this was the first year that Wireless Emergency Alert (WEA) would be integrated into the national test and that the alert would appear on mobile devices as "Presidential Alert".
• Overall, radio had a 78.7% participation in this year's test.  This is a slight increase from 78.5% in 2017.
• LPFM's participation this year was 48.4%, this is a slight decrease from 48.5% in the previous test.  
• Of the 3,802 radio broadcasters that failed to file in the 2018 test, 1,121 (29%) of these stations were LPFMs.  
• LPTV (Low Power Television) had a massive slump in participation this year falling from 66.3% in 2017 to 41.5% in the most recent test.
• For the second year in a row, low power broadcasters (LPFM and LPTV) were called out for "[reducing] the overall participation rate of all broadcasters".
• Of the 962 LPFMs that did participate, 869 (90.3%) successfully received the alert and 789 (82.0%) successfully retransmitted the alert.  By comparison, in 2017, 92.5% of stations received the alert and 83.8% did rebroadcast it.

Last year, I had written to Lisa M. Fowkles, Bureau Chief of Public Safety and Homeland Security to address the issues that LPFM stations are facing. In that letter, I had made some recommendations including those that came from constituents.  This included sending out postcards to LPFM stations prior to the test to remind them of their EAS obligations and their need to participate in the National Test.  I had also suggested that EAS related news releases, orders and other documents should be flagged as both Public Safety/Homeland Security and Media Bureau in order to assure that news aggregators such as REC's fcc.today, RSS news readers and those going directly to the Media Bureau for updates can still receive critical updates to EAS.  I had also mentioned the cost involved with EAS equipment and software updates and had suggested that the FCC and FEMA be more open to allowing open source EAS systems as well as making the output of IPAWS truly open in a manner that it can be used by decoders without the need for a memorandum of understanding but in a manner that the network is secure from false intrusive messages.  This is similar to how Canada does it.

I am glad to see that the Bueau has taken some of this letter into consideration.  I am happy to see a bullet point that the Bureau needs to "[r]each out to Low Power broadcasters through a variety of means, including directed mailings and a webinar, to improve their participation in the nationwide EAS test."   I totally agree with the directed mailings.  I am not sure that a webinar would help here.  The issue is because of the six segments and because of how many of these LPFM stations operate merely as "translators" for satellite networks (EWTN, Three Angels, New Tang Dynasty, etc.), many of these stations, especially in rural areas either don't have a working EAS or they do but there is no real local responsible party taking care of the day to day needs of the station.  In other words, they set it and forget it like a translator. 

I do want to have a meeting this year with the PSHSB, either face-to-face or by conference call to discuss a strategy for improving EAS awareness.  The NAB is using various tactics to highlight LPFM's overall compliance record to oppose technical changes proposed by REC to benefit the LPFM service (while ignoring certain licensees of full-service stations with deplorable compliance records, looking in the direction of the 713 area code). So yes, LPFM's overall participation does not shine a good light on our service, especially as we try to improve it in order to better reach our listeners. I do feel that our true community-based LPFMs (e.g. those who attend the GRCs and are involved in the various discussion forums) are the stations that are properly equipped and therefore participating in the tests.  My main concern falls on the LPFM stations that are used as satellite feeders for EWTN, etc. and those that are used for strict public safety traveler's information, such as the ones in the State of Colorado.  I really wish the FCC would release this data freely, at least to stakeholders.  I have no plans of filing FOIA requests at this time.  

This is just a reminder to all LPFM stations, regarding of which segment the station is in.  Please make sure that your EAS is functioning, the receivers are tuned to the correct stations in accordance with your state EAS Plan and you frequently check your log (once per week) to make sure that your EAS is receiving the weekly and monthly tests.  LPFM stations are not required to rebroadcast the weekly tests but they are required to rebroadcast the monthly ones.  If you are unable to receive one or more of your EAS assignments, you must contact your state's EAS coordinator for a "waiver" and an alternate monitoring assignment.  

Also, please follow the REC LPFM Station Inspection Checklist training.  There is a lot of information in there about EAS compliance.   Of course, if you have any questions, you may always contact REC for advice.

To the 962 LPFM stations that did participate in last year's test, thank you.