Last week, the Federal Emergency Management Agency (FEMA) formally notified the FCC that FEMA has scheduled the next nationwide test of the Emergency Alert System (EAS) for August 7, 2019 at 2:20 p.m. FEMA states that this year’s test will differ from the nationwide tests that have been conducted over the past several years in that it will be issued through the National Public Warning System, composed of FEMA-designated Primary Entry Point facilities, to test the readiness of the EAS to function in the absence of Internet connectivity.
In other words, the August test is dependent on the ability of EAS to operate without a ‘net, reaching EAS Participants solely by over-the-air means. The initial report from FEMA and the FCC following the 2018 Nationwide EAS Test noted that almost 60% of participants received the test announcement first via the Internet-oriented Integrated Public Alert and Warning System (IPAWS), a significant increase from 41.9% in 2017.
Also unique this year is the timing of FEMA’s announcement. For the 2016, 2017 and 2018 tests, FEMA and the FCC announced the date of the proposed test in July and held the test in September with an October backup date. As a result, the 2019 test will be performed significantly earlier in the year compared to prior tests. The choice of this date is interesting in that it falls at the end of peak tornado season for much of the Midwest, and the beginning of peak hurricane season in the Southeast. Last year’s test was postponed to the backup date in October because of Hurricane Florence, which made landfall in September. This year’s date may, however, present a challenge to full participation in the test by student-run college stations, which may not operate during summer recess.
In terms of related regulatory obligations, broadcasters have generally been required to file an FCC Form One 30 days in advance of the actual test. That filing is usually followed by a Form Two filing on the day of the test and then a Form Three filing 45 days after the test. The exact information sought on the forms often varies year-to-year, but the filing system itself has found a permanent home on the FCC’s electronic EAS Test Reporting System (ETRS). ETRS has not yet been updated to provide information for the 2019 Nationwide EAS Test, so the required forms (including submission due dates), updates in requested information, and any changes to the way in which the forms are to be filed have not yet been made available.
Being so broadcast station-dependent, this year’s test will place an even brighter spotlight on radio and TV stations, as any failures in receiving and relaying the National Periodic Test announcement may be laid at the feet of broadcasters. Stations should therefore be alert to the imminent announcement of filing due dates and other information surrounding this year’s Nationwide EAS Test.
Stations should also take this opportunity to ensure that their EAS equipment is not obsolete, is fully installed, is in working order, is set to monitor the correct EAS sources, and has had the latest software updates downloaded and installed. It would also be a good time to review EAS procedures with station staff to avoid past problems such as continuing to run program audio behind the test message. Each of these were identified as points of failure in FEMA’s reports following the prior Nationwide EAS Tests.