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Working Group #9 CAP Implementation

Working Group #9 CAP Implementation. March 22, 2012 Co-Chair Chris Homer Co-Chair Ed Czarnecki . Working Group #: Name.

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Working Group #9 CAP Implementation

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  1. Working Group #9CAP Implementation March 22, 2012 Co-Chair Chris Homer Co-Chair Ed Czarnecki

  2. Working Group #: Name • Description: The immediate focus for Working Group 9 is to review the Fifth Report & Order (released January 10, 2012) on CAP deployment, provide recommendations and best practices to the FCC and CAP implementation progress through 2012. • Duration:  • First Report March 2012 • Second Report December 2012

  3. Working Group Deliverable Timeline Working Group 1 D = 12/5/11 F= 12/5/11 V = 12/8/11 Working Group 2 Working Group 3 Working Group 4 Working Group 5 Deliverables:D= 2/23/12, F= 3/8/12, V = 3/22/12 Deliverable s: D= 5/9/12, F= 5/23/12, V = 6/6/12 Deliverables: D= 8/15/12, F= 8/29/12, V = 9/12/12 Deliverables: D= 11/7/12, F= 11/21/12, V = 12/5/12 Working Group 6 Deliverables: D= 2/6/13, F= 2/20/13, V = 3/6/13 Working Group 7 Working Group 8 Working Group 9 Working Group 10 V = TBD D = draft report to Steering Committee F = final report to CSRIC Members V = Vote by full CSRIC

  4. Working Group 9 –Participants • Jeb Benedict, CenturyLink • Jeff Staigh, Univision • Jim Gorman Gorman-Redlich • Kelly Williams, National Association of Broadcasters (NAB) • Larry Estlack, Michigan Association of Broadcasters • Matt Straeb, GSS • Michael Hooker, T-Mobile • Mike Nawrocki, Verizon • Ron Boyer, Time Warner Cable • Tim Dunn, T-Mobile • Eric Ehrenreich, FCC • Alfred Kenyon FEMA • Andy Scott, National Cable Television Association (NCTA) • Bill Marriott, ComLabs • Bill Robertson, DAS • Bob Sherry, Intrado • Chris Homer, DirecTV (Chair) • Clay Freinwald, Washington SECC • Daryl Parker, TFT • Donald Walker, GRM • Edward Czarnecki, Monroe Electronics (Co-Chair) • Gary Timm, Wisconsin SECC • Harold Price, Sage Alerting Systems

  5. Working Group 9 - Executive Summary • The Emergency Alert System is the primary warning system that provides the President with the means to address the nation during a national crisis. • On May 31, 2007, the FCC adopted a Second Report & Order to require EAS participants to accept messages using CAP digital delivery. • On January 10, 2012 the FCC released the Fifth Report and Order which further clarified the process to receive and transmit CAP messages for the EAS, and to streamline the Part 11 rules. • A specific area of investigation by WG9 pertains to the impact of the FCC’s Fifth Report and Order on EAS (released 10 January 2012) on CAP EAS migration.

  6. Working Group # 9 - Findings • The FCC Fifth Report and Order disallows the use of text-to-speech conversion technology on and CAP EAS device (at least pending a future proceeding). • It does concede the potential use of such technology by CAP originators themselves. • We observe that several CAP-based EAS origination and relay systems, including FEMA IPAWS, rely on the use of Text to Speech technology. • It was noted that the National Weather Service is preparing to feed CAP to IPAWS by April 2012, but also will rely on use of Text to Speech. • Furthermore, at least one deployed and operational CAP relay system is similarly predicated on the use of text to speech by EAS devices. • We noted that the absence of Text to Speech technology could compromise alert message usability, if it was not available as a backup capability if an audio file was absent or unusable.

  7. Working Group # 9 - Findings • EAS Device Certification • The working group examined the revised CAP EAS device certification process in depth. Three classes of CAP equipment were created by the Commission: • Integrated CAP EAS encoder/decoders • Universal intermediary devices • Component intermediary devices

  8. Working Group # 9 - Findings • Implications of “Streamlined” Process for Integrated CAP EAS devices • Subcommittee consensus that the report and order indicates that integrated CAP EAS devices are required to submit a class II permissive change filing, plus a copy of an SDoC. • The consensus among subcommittee members was that universal intermediary devices holding a valid SDoC had a reasonable possibility of meeting the Part 11 certification requirements by 30 June 2012, provided that the Part 11 testing regime was “on line” at the earliest possible time. • The consensus among subcommittee members was that universal intermediary devices that hold neither a valid SDoC nor Part 11 certification, may face challenges in meeting the certification requirements by 30 June 2012, given the remaining timeline.

  9. Working Group # 9 - Findings • Potential issues of combining IPAWS Conformity Assessment with FCC Part 11 Equipment Certification • Among other issues, the FEMA CAP conformity test guidance – needed for test facilities to review and design of their test support programs - has not yet been publicly posted. • Nonetheless, completion of Part 11 testing of products with an existing valid SDoC/Test Report is feasible by June 30, 2012. • There was broad consensus that this situation does not warrant any extension to the 30 June 2012 CAP compliance deadline.

  10. Working Group # 9 - Recommendations • Text to Speech WG-9 recommends “Text to Speech” Prohibition be removed for the following reasons; • At a minimum, it would enhance alert message usability as a backup, in the event that an audio file was absent or unusable. • It would increase the overall success of CAP rollout for participants based on current findings. • It would allow a more diverse group of providers to participate. • It would reduce operational costs for alert originators, in terms of total bandwidth required by CAP Originators, CAP disseminators, and EAS Participants • It would prevent unplanned costs for Originators (typically State, Local, Tribal and Territorial government agencies), who would have to either acquire or alter their existing systems to originate high quality audio.

  11. Working Group # 9 - Recommendations • WG-9 recommends that the FCC incorporate the EAS-CAP Industry Group Implementations Guidelines on “Text to Speech” • Provides for the ability to process an audio file in a specified format for EAS voice. • Provides for text to speech conversion in the event, for whatever reason, that audio file is unavailable or unusable.

  12. Working Group # 9 - Recommendations • Device certification • Recommend that contents of paragraphs 170 and 171 in the Fifth Report & Order be incorporated into the amendments of Part 11. • Recommend that FCC require submission of BOTH a vendor supplied SDoC and third party CAP Conformance Test Report (i.e. IPAWS CA or TCB). • Recommend that all testing under the streamlined certification process be conducted in accordance with §11.34, and Certified in accordance with the procedures in Part 2, Subpart J (47 CFR 2), via an FCC-approved facility. • Recommend that any other self-certification be disallowed, as being inconsistent with the procedures set forth in Part 2, Subpart J. • Recommend that FCC testing ensure certifications relate to the specific product combination (hardware model + software version) that was actually tested. • Recommend that that FEMA issue its CAP conformity test guidance as quickly as possible, so that prospective laboratories may begin review and design of their test support programs.

  13. Working Group # 9 - Recommendations • WG-9 recommends that the 30 June 2012 deadline remain in place.

  14. Working Group # 9 – Best Practices • If the “Text to Speech” prohibition remains in effect • EAS participants should confirm with their respective equipment vendors to ensure system firmware/software versions are up to date and the text to speech option is disabled. • EAS CAP equipment manufacturers should provide guidance to EAS Participants, as soon as practical, as to how the text to speech option can be disabled on each respective version of equipment. • Federal agencies (FCC and FEMA) should develop additional specific best practices and guidance for by (a) CAP EAS alert origination systems (b) users of such equipment (state, county, local, tribal and territorial) on making audio files (mp3) available locally. • Local Government and CAP system developers: If audio files on remote servers are to be relied on as the source for EAS audio, then developers should consider how that audio can reside in a trusted environment where the content would not be compromised before, during or after an alert event.

  15. Working Group # 9 – Best Practices • If the “Text to Speech” prohibition is rescinded • EAS participants: Should work with their respective manufacturers to identify and wherever possible remediate any significant inconsistencies or errors in pronunciation, etc. • EAS CAP equipment manufacturers: Should voluntarily and proactively respond to any significant inconsistencies, errors in pronunciation, or local lexicon. • Local Government and CAP system developers: Should follow best practices, for example as contained in FEMA training course IS-247, to ensure as much as possible that the CAP text message being delivered should not contain jargon, acronyms, and letter/number.

  16. Working Group # 9 – Best Practices • CAP EAS Equipment Certification • EAS Participants: Should coordinate with their respective equipment manufacturers on the process under which their equipment will meet the required streamlined certification process. • Equipment Manufacturers: Should take early steps to prepare for their requirements under the streamlined certification process, so that they provide themselves and customers with the least level of risk. • FCC: Should ensure that equipment certifications relate to the specific product combination (hardware model + software version) that was actually tested. • FCC and FEMA: Should coordinate closely on preparation of facilities supporting the streamlined certification process. • FEMA should issue the CAP conformity test guidance as quickly as possible, so that test facilities may review and design their test support programs. • The FCC should continue the use of certified third-party test facilities for both Part 11 and CAP conformance testing (per 47 CFR Part 2, Subpart J).

  17. Working Group # 9 - Next Steps • Monitor progress of CAP Implementation • National Level • State Level • Local • Track Issues • Topology • Capacity/Availability • Security • Reliability

  18. Tentative - Project Timeline FCC CAP Deadline 6/30/2012 2012 2013 Nov Dec Jan Feb Mar Apr Nov Dec Jan May Jun Jul Aug Sep Oct WG9 Kickoff Meeting WG9 Report - TBA: 12/16/11 CSRIC Meeting Friday, 12/16/2011 WG9 Implementation Report: 12/5/12 CSRIC Meeting Friday, 12/5/2012 CSRIC Meeting Weds, 9/12/2012 CSRIC Meeting Thurs, 3/8/2012 B/P Target Date CSRIC Meeting Weds, 6/6/2012 Final CSRIC Meeting Wednesday, March 6, 2013

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