Wireless Industry, Public Safety Groups Clash on Proposed Changes to WEAs

APCO supports enhancements proposed by the FCC and “would go further, requiring participating service providers to support any type of multimedia that is in common use by consumers,” it said: There’s a “robust record” demonstrating “alerting authorities’ desire to incorporate multimedia content in WEA messages and that it is technically feasible to do so. … Virtually any alert could be more effective with multimedia content to quickly and intuitively convey critical information.”

APCO also supported changes aimed at making the WEA process more transparent. As the FCC observes, “the WEA system is being under-utilized due to alerting authorities’ lack of confidence in the WEA system,” APCO said. “Consumers and alert originators will place more trust in WEA messages when their experiences are uniform across devices and service providers,” the group said.

WEAs need to be more transparent and more accurate in the geographic areas they reach, said public safety agencies in Colorado. “We use WEA to cast a wide net,” the agencies said. “Right now, WEA is not a precise or surgical tool that allows us to target a subdivision or an apartment complex.”

“We support the proposals that would establish a publicly accessible WEA Database and which would improve the reporting requirements for … providers,” said the New York State Division of Homeland Security and Emergency Services. Limiting the language requirement to the 13 most commonly spoken languages, in addition to English, “would leave significant gaps” for New Yorkers, the state said: “For example, Bengali is the 5th most commonly spoken language in New York State, while it is 17th” in the U.S.

Industry Pushback

CTIA said some proposals in the FNPRM aren't easily workable for providers. The group said proposed automated performance reporting requirements for WEAs are “incompatible with the one-way, cell-broadcast technology that is a central design feature which has been critical to the success of WEA.” The system used to broadcast alerts “does not have an acknowledgment mechanism and the cellular system does not track wireless devices -- Participating … networks simply act as a vehicle to broadcast alerts and lack visibility into whether devices receive or display” them, CTIA said.

Reporting requirements would raise data concerns and lead to consumers opting out of alerts, CTIA warned: “Many users will not understand and will assume they must opt-out of receiving any alerts to avoid having their movements and private information tracked.” Other enhancements would cause network problems, the group said. “Adequately managing even small multimedia content would require a fundamental change to the cell broadcast standard and a time and resource-intensive global standards effort to maintain interoperability and roaming, while adding substantial delay to delivery of critical, life-saving messages,” CTIA said.

ATIS’ Wireless Technology and Systems Committee expressed “strong reservations” about “the utility of WEA performance minimums to improve WEA reliability and effectiveness, as well as the technical feasibility of applying such performance minimums to each WEA message.” The committee said alert originator-provided embedded links are “the only feasible way to provide multimedia content,” and other added content would “negatively impact WEA performance reliability and latency.”

Some proposals, including multilingual alerts, map presentations and other enhanced content, and a standard rebroadcast interval, could improve alerts, Verizon said. But the FNPRM “also envisions potential rule changes that would go too far; they would imply or require a redesign of the WEA system from a one-directional, cell broadcast-based text delivery system to a multimedia-based system with multidirectional capabilities even more dependent on the processing and performance capabilities of wireless handsets,” Verizon said: “The WEA program would move further away from a traditional warning and alerting system toward an individual consumer-driven ‘opt-in’ feature -- both of which have public safety merits and drawbacks the Commission should carefully weigh.”

The FCC should “carefully balance the benefits of pursuing new capabilities against the potential disruption to a highly effective system that provides actionable and timely emergency information to wireless users,” said AT&T: “The Commission also should ensure that any new capabilities are implemented through the collaborative, global standards-based approach and recognize that cell broadcast technology remains critical to the success of WEA.”

Including multimedia content in every WEA message “is not feasible because it will decrease performance of the WEA system,” T-Mobile warned: “Merely adding a thumbnail photograph into a WEA message will increase the number of broadcast segments needed to convey the message, which increases both latency and the probability of errors.” Any required performance metrics “must be consistent with WEA architecture,” the carrier said.

The Competitive Carriers Association questioned whether the FCC can permissibly rely on the Warning, Alert and Response Network (WARN), which established WEAs in 2008, as the basis for new rules. “As CCA suggested in the WEA Security NPRM proceeding, this delegation of authority to the FCC was time-limited and the FNPRM’s proposals potentially go far beyond Congress’s intent in the WARN Act,” the group commented. CCA members also have “significant concerns regarding the reliability and maturity of the some of the technology associated with the FNPRM proposals, the potential unintended or negative network impacts associated with implementation of the proposals, and technical constraints impeding industry compliance with the performance and reporting proposals contained in the FNPRM.”