What is really wrong with EAS?

Aside from it hasn’t worked… Over the last several, the FCC has released no fewer than five proceedings regarding EAS.  To date, few, if any meaningful changes have taken effect.  The stated purpose of the Emergency Alert System (EAS) is to:

  1. provide the communications capability to the President to address the American public during a national emergency.
  2. may be used by state and local authorities to deliver important emergency information, such as AMBER alerts and weather information targeted to specific areas.

Seems pretty straight forward.  Local weather emergencies would seem to be the most likely reason for EAS activation, followed by things like Amber Alert, chemical spills, evacuations, etc. To meet those ends, the FCC mandates that radio (traditional and IBOC), television, cable, wireless cable, direct satellite TV, and satellite radio participate in some way or another.  So far, it seems like a fair idea.  Then comes the implementation, which is flawed. To start with, EAS still relies on a daisy chain relay system designed during the 1960’s for CONELRAD.  The over the air monitor assignments of other broadcast stations are the only mandatory information sources in the system.  Other, more relative local sources such as the national weather service, local government and so forth are optional. Next, the most used and most useful part of the EAS, local and state level alerts are completely optional.  Very little or no information is provided to local government agencies on how to access EAS in the event of an emergency.  Then the issue becomes one of un-maned stations.  The initial EAS message goes out over the airwaves, which takes about 2 minutes at most, then it’s back to the music.  No amplifying information, check back for more information when it becomes available, etc.  Nothing.  It has occurred in several cases where a radio show is voice tracked, complete with a weather forecast, which is the opposite of real time weather warnings.  If one happens to miss the initial EAS broadcast because they were listening to another station or whatever, well, too bad. Finally, the National Weather Service itself over activates.  One line of summer time thunderstorms passing through the area can trigger 10 or even 20 EAS alerts.  Over activating, with the same digital tones (rrrrrrannk, rrrrrrank, rrrrrank) followed by the EBS tone then some computer generated voice just gets annoying. To summarize:

  1. The national EAS has never been tested, who knows if it will work
  2. The EAS relies on unreliable over the air daisy chain relays for it’s mandatory monitor assignments
  3. Local and State level EAS (including weather related alerts, something that could be really useful) is optional
  4. When connected to the NOAA weather radio system, the NWS over uses the EAS activations

Here is an idea:  For at least ten years now, the idea of a CAP has been batted around.   It seems like a good idea, lets do that.  Get rid of EAS, send emergency information to everyone’s cellphones or whatever and stop fining broadcasters for missing a monthly test.  The weak link in the EAS is the broadcaster’s themselves.  History has shown (over and over again) that the current crop of radio station owners cannot be bothered to meet even the simplest of their public obligations.  The FCC has shown it is only interested in collecting big fines for a missed EAS tests, not actually making the system work.  The system is broken.  As terrestrial radio (and TV) goes terminal, the public will still needs to receive emergency information, the CAP idea can fill this requirement. It is time to pull the plug on EAS once and for all.

S.2881 – FCC Commissioners’ Technical Resource Enhancement Act

The house version of this bill is HR 4809.  It seems that in this day and age, as the country is becoming more and more technologically advanced, the communications regulation arm of the federal government is feeling a little left behind.  This is a fairly common thing these days, companies are run by accountants and lawyers while the engineers and technologists that actually do what ever technical thing the organization is supposed to be doing are “those funny guys in the basement” or corner or wherever.  The bill reads as such:

Section 4(f)(2) of the Communications Act of 1934 (47 U.S.C. 154(f)(2)) is amended by inserting after the first sentence the following new sentence: ‘Each commissioner may also appoint an electrical engineer or computer scientist to provide the commissioner technical consultation when appropriate and to interface with the Office of Engineering and Technology, Commission Bureaus, and other technical staff of the Commission for additional technical input and resources, provided that such engineer or scientist holds an undergraduate or graduate degree from an institution of higher education in their respective field of expertise.’.

That would be a step in the right direction.  Hopefully said engineer has several years of experience also, field experience would be even better.  As a radio engineer, I learned that theory is great and most of the time everything goes together exactly as it is supposed to.  There are those occasions, however, where theory has to be thrown out and a prove-fail/prove-pass approach needs to be taken.

In any case, the bill appears to be on the fast track and hopefully the FCC commissioners will choose and use their staff engineers wisely.

I-Buzz

Rumor has it that iBiquity is going to release a software upgrade for the AM IBOC system they peddle.  Allegedly it is going to improve the sound quality of the digital signal, allow the analog signal to increase it’s bandwidth to 10 kHz and provide data such as song titles.  No word on whether they will be providing software upgrades to consumers for the many HD radioTM receivers out there.

I have been following a discussion on AM quality over the last few days.  It seems many engineering types at least, acknowledge that analog AM can sound good, if not more natural that FM.  The addition of IBOC hybrid mode on AM station has created more noise and further degraded the station’s main signal by reducing the bandwidth to less than 5 kHz.

Tonight I am listening to WWVA on 1170 kHz, and there is this horrific white noise/hash over top of the station.  Same thing on 1190 kHz, all courstesy of WHAM 1180’s IBOC transmission.  It is one thing to trash your own station, limiting the analog audio response to 5 kHz.  It is quite another thing to trash the adjacent frequencies with noise making them unlistenable.

Here is a brief clip (recorded at 8:00 pm EDT, March 24, 2010):

Second clip, WWVA has faded out (recorded at 9:10 pm EDT, March 24, 2010)

The audio in these videos is adequate but not the best, still, it is pretty clear that there is a whole bunch of white noise on top of WWVA’s signal and on 1190 where no station is coming in. The only conclusion that I can draw is that WHAM is operating with their IBOC turned on. This was recorded at a location that is 197 miles from WHAM and 364 miles from WWVA.  I have made several better recordings directly into the computer without the video frequency readout reference.

In 1990, the FCC mandated NRSC-2 (73.44) spectral mask on all AM stations, requiring them to put in brick wall filtering to limit the bandwidth to 10 kHz or less.  They also require all AM station to do “equipment performance measurements” (73.1590) to verify that the stations are complying with FCC regulations.  This was done because of excessive sideband splatter by AM broadcasters creating interference to adjacent channel stations.  I agree in principle with the NRSC-2 standard, I think it serves a purpose.  Why then, are stations allowed to interfere with other stations with IBOC signals?  Even though Ibiquity has put up a spectral mask that complies with NRSC-2, it still creates interference.  Isn’t this a double standard?  A station in Pennsylvania gets fined $4,000.00 for operating past its sign off time (because operating after sign off might create harmful interference), yet, WHAM gets to generate noise all night and drowned out adjacent channel stations that are hundreds of miles away?

In the mean time, if the FCC inspector shows up at a station that has not made the required “equipment performance measurements” they will get a fine too.

Am I crazy, or is it hypocritical bull shit to fine one station for potential harmful interference, but then the FCC to ignores its own rules and allows another type interference?  Hint: I am not crazy.

I have recorded this in .wav format and I am sending it to the FCC with an interference complaint letter.  It is about time somebody made some noise about this noise.  Apparently, there are many engineers who feel the same way.  Will Ibiquity listen, or will they keep doing CPR on a corpse?