REC opposes Rosenworcel's multi-lingual EAS plan - suggests a voluntary method to improve alerting towards non-English speakers

Edited April 10, 2024 to correct link to the FCC Notice of Proposed Rulemaking.

In comments filed with the FCC, REC Networks urges the Commission to not move forward with their proposal to require broadcast stations, including LPFM and other small broadcast stations to upgrade their Emergency Alert System (EAS) decoders in order to support the transmission of alerts in 13 different languages, which were determined by the US Census Bureau to be the top 13 non-English languages spoken in the United States.  This proposal is the latest “pet projects” of FCC Chairwoman Jessica Rosenworcel to improve the accessibility of EAS.

Under the FCC’s proposal, radio and television broadcasters would be required to install the appropriate programming and files necessary to support alerting in Arabic, Chinese, French, German, Haitian Creole, Hindi, Italian, Korean, Portuguese, Russian, Spanish, Tagalog and Vietnamese as well as American Sign Language (ASL).  While EAS decoders would be required to have this capability, only stations that broadcast in any of those languages would be required to actually deploy alerts in the language that they are broadcasting in.  In the Notice of Proposed Rulemaking, which was worded more like a Notice of Inquiry, the FCC proposes different methods of delivering alerts, such as the use of pre-recorded “template” messages that would run based on the type of alert that was received (such as tornado warning, child abduction emergency, monthly required test, etc.). 

In opposition, REC stated that while it may be in the public interest to tailor alerts to the language of the broadcast station, it is not practical from a systems development standpoint as well as from an economic standpoint.  REC reminds the Commission that their recent mandate for broadcast stations to implement “CAP Polling” resulted in a software/firmware update that cost every station in the hundreds to thousands of dollars to achieve as well as the resource time needed to update the tens of thousands of EAS decoders currently in the field.  REC noted that LPFM and other small broadcast stations are still “feeling the burn” from that upgrade, which provided no substantial benefit to radio broadcasting. 

REC points out that the entire concept of preloading the audio files, the additional font files (for television crawls) and the video files for ASL support may require the installation of additional hardware by the broadcaster.  REC stated that because of the amount of storage that is required will definitely result in an expenditure that would have to be absorbed by the broadcaster, especially in the absence of a Congressional mandate and underlying appropriations to fund the development and deployment of this multi-lingual capability, which for a large number of radio broadcasters would, like CAP Polling, would result in no true benefit as radio stations that broadcast in English would not have to use the capability (TV stations would benefit from the addition of ASL).

We also point out the specifics of certain languages from a software design perspective.  Languages such as Chinese and Korean use multi-byte characters and without substantial changes in programming may not be supported in the same way that Latin character sets (such as those used in English and other European languages) are supported.  We also explain how multi-lingual text to speech and language translation may be ineffective and in some cases, could result in either the broadcaster or the manufacturer having to obtain text to speech and translation services from an outside company’s application programming interface (API), which could result in monthly subscription fees that will need to be passed on to the broadcaster.

REC also expressed concern that the use of “template messages” may leave out critical information from the English messages that would be missed in the template recording.  REC makes note that the Commission provided no statistics on the percentage of those who speak one of the Top-13 languages also has a level of English fluency, even a very basic knowledge of the language.  For example, tornado warning messages from the National Weather Service are very detailed on what locations within a particular county could be impacted. REC reminds the Commission that even if a text to speech method was viable, it would not work for a majority of the alerts as the National Weather Service does not use the Integrated Public Alert Warning System Open Platform for Emergency Networks (IPAWS-OPEN) and therefore can only deliver the county and the event type through datacasting.

Instead, REC proposes that broadcasters, especially radio broadcasters, should be permitted to voluntarily implement multi-language alerting and to only be required to be equipped with the specific language they broadcast in.  REC suggests that EAS participants that want to participate should be able to record their own template messages in the appropriate language for their station.  Such a method would permit the support for other languages other than the Top-13 languages, including indigenous languages spoken in Tribal nations.

Overall, REC opposes the plan as proposed as a massive economic burden on broadcast stations of all sizes, especially small stations. 

Reply comments in PS Docket 15-94 are due Monday, May 6, 2024.