BE Radio May/June 1995 Analysis Counterpoint on EAS By William Fawcett What will the real cost of implementing EAS be, and who will pay it? ----------------------------------------------------------------- THE BOTTOM LINE: By now you've probably heard about the new Emergency Alert System and its advantages, but how much do you really know about it? While its predecessor, EBS, can certainly stand the update, close inspection shows that EAS may also have its problems. Among these are the cost of new equipment, the optional nature of several key features and the inclusion of burdensome requirements. Finally, will EAS actually help the public be better informed? ----------------------------------------------------------------- The new climate in Washington may be calling for reinvention and downsizing of government, but in the opinion of some observers, the sweeping revision of the EBS system that is about to take place is anything but less intrusive. Broadcasters should take heart -- it's the cable operators who are in for a real shock. An appended Further Notice of Proposed Rulemaking may in some instances require cablecasters to provide bed-shakers for handicapped customers. On balance, the new system will probably provide some necessary improvements to the country's emergency alerting procedures. In certain situations it also may enable true walk-away operation for stations. But nothing comes without a cost. Compared to what The Commission calculates that "the entire cost of the new EAS equipment to the broadcast industry...could be as low as $8.7 million." But this is based on estimated costs of hardware that may be lower than what the eventual products actually cost. The EAS R&O also estimates that the new EAS could save 10% of weather-related deaths and injuries, and 1% of weather-related property loss and damage, which in 1992, "would have meant that 31 lives could have been saved 324 injuries and $384 million in property damage could have been avoided." Even if you accept that estimate, this public service at the expense of broadcasters must be considered either an indirect tax or a mandated contribution. But elsewhere in the R&O the Commission figures it will come out in the wash: "One commenter estimates...that the new system would provide a median annual operating savings of $5,280 per station. Thus, operating savings alone may pay for all or most of a broadcaster's cost to install and operate the new EAS." This commenter is unidentified in the R&O, but from other sources, it has become clear that the commenter based these figures on lost commercial airtime and the cost of record-keeping, staff training and maintenance required by EBS that will not occur under EAS. This makes several assumptions, including that the newly available airtime under EAS will actually be sold by stations, and that the other costs will actually be so significantly reduced. In terms of actual cash outlay, no station spends more than a few hundred dollars a year on average for EBS operations, and ongoing EBS equipment costs are negligible, so many stations may be hard pressed to balance their ledgers using the Commission's reasoning. The costs of complexity To prevent bogus transmissions (which already is a federal crime) the EAS's FSK keying scheme uses non-standard keying and data rates, just complicated enough to prevent off-the-shelf modem software and hardware to be used (although not presenting much of a challenge to a ham operator experienced in packet communications). The complexity of the system approaches that of one of the integrated wire service/computer services, or a satellite/computer weather service, where a station's hardware cost typically runs around $3,500. Will the quantity of production really drop costs far below this, as the Commission expects? It could also be argued that the complexity of the system (and the limited market size) will keep some potential manufacturers out of the market. Such a small number of vendors could keep the price artificially high. Because no product has been type-approved by the FCC as of this writing, manufacturers are not yet quoting firm prices, but their estimates for complete encoder/decoder systems (which most stations will require) run around $2,500. Your mileage may vary. Other hidden costs are also involved: The new system requires at least two monitoring assignments instead of one. Low-end encoder/decoders will require additional receiver(s) and, in many cases, additional yagi antennas. Stations operating distant repeater-type stations by remote control may have to locate this equipment at the transmitter site, and the tower rent for installing a yagi could easily be another $300 a month. A UPS-type power supply is probably warranted for the EAS hardware, along with a PC and modem (if one is not already on hand) to access the EBS database for copies of statewide plans. (You could get these by mail, but the PC will likely be necessary anyway because the NPRM on unattended operation proposes a computer bulletin board to keep your contact-person registration current.) The EAS also allows optional automation, which can solve the common EBS problem of operators not hearing alerts (or not knowing what to do). Unfortunately, the stations who can only afford entry- level operators -- which need this feature the most -- are likely to purchase the cheapest systems with the fewest automatic features. Impact on AM daytimers The EAS disproportionally burdens daytimers. The new system schedules half the monthly state system tests when many AM stations are off the air: "Tests in even numbered months should occur at times other than between 8:30 a.m. and local sunset." How will AM stations know when they have to keep someone on late just to run a test? How will listeners react to (or benefit from) stations coming on in the middle of the night, running a test, and signing off? What will the additional expense to AM stations be? How fast a track? The FCC is on a fast track toward EAS, as Table 1 indicates. Will the date(s) be delayed, like the STL bandwidth restrictions? Probably not. The astute manager will wait until early next year to order equipment, just to give the market time to react. But massive back-orders could occur during those last six months before the July 1, 1996 deadline, and given the complexity of the system, it could take a year beyond that until the system's bugs are worked out. Will the EAS accomplish what it sets out to do? Will consumers, as the FCC envisions, buy hardware that will wake them up in the middle of the night when an EAS alert is received? Consumers can presently purchase NOAA weather receivers and tabletop radios with dual-tone decoders, but they have not been big sellers. Unless mandated, demand for such items will probably not increase. If a radio station tones-out in the middle of the night and nobody hears it, will "$384 million in property damage" be avoided? Typically, after such sweeping regulation as this, the FCC later clarifies its intent by memorandum. (NRSC is a recent example.) This will likely be the case again with EAS. But just as with NRSC, PCBs, STLs and so on, the expense of this experiment will sit squarely on the shoulders of the broadcasters. Table 1. The EAS conversion timetable for broadcast stations. EAS TIMETABLE - BROADCAST STATIONS --------------------------------------------------------------------- Requirement | 11/10/94 | 7/1/95 | 7/1/96 | 7/1/97 ---------------|----------------|------------|-----------|----------- Two-tone | 20-25 | 8-25 | 8-25 | 8-25 encoder timing | seconds | seconds | seconds | seconds _______________|________________|____________|___________|___________ Two-tone | Begin changing | All | 3-4 | Two-tone decoder | timing from 8- | decoders | sec. | decoders timing | 16 to 3-4 sec. | at 3-4 | | no longer | | sec. | | used _______________|________________|____________|___________|__________ EAS decoder | Use is | Use is | Use is | Use is and encoder | optional | optional | required | required _______________|________________|____________|___________|__________ Table 2. Manufacturer's recommended modifications for EBS decoders, to conform to shortened two-tone alert signals. After July 1, 1995, all EBS decoders must be set to respond to these shorter tones. --------------------------------------------------------------------- How to shorten EBS decoder timing: Gorman-Redlich: All models: Change the summing point time-constant capacitor (47mf tantalum) at the junction of two diodes feeding IC8 pin 2 to a 10mf tantalum. You may need to hand-select the exact value. McMartin EBS-2: Replace R37 (470k ohm) with a 500k ohm pot (wiper and one end). Adjust to approximately 255k ohm. Alternatively, parallel R37 with a 560k ohm resistor. Absolute value may vary, because timing is dependent on actual value of C24, which is a 200mf capacitor. Multi-Technical Services: All units: Replace microprocessor chip, available from factory for $125.00. TFT 760 series: Replace C13 with a 22mf 5% 25v tantalum capacitor. Replace R26 with a 182k ohm 1% 1/4W resistor. Contact TFT to request "A Primer: Guide to the new Emergency Alert System." TFT 886/887 series: Locate SW10 on the main PCB. Turn all switches OFF, then turn SW10-2 ON. Contact TFT to request "A Primer: Guide to the new Emergency Alert System." --------------------------------------------------------------------- --------------------------------------------------------------------- For further information: You can obtain the FCC's EAS Report and Order electronically via World Wide Web, Gopher or anonymous FTP: Gopher fcc.gov December 8, 1994