EAS Test Reporting System Form One Due by Feb. 28

posted on 1.03.2023

- TAB Protests FCC’s Proposed Cybersecurity Rules

The FCC is getting an early start to the annual filing by radio and television broadcasters of Form One into the online EAS Test Reporting System (ETRS).

ETRS opened this week to allow filing of Form One.

Broadcasters have until Feb. 28 to do so as outlined in a FCC Public Safety and Homeland Security Bureau Public Notice issued last month.

The Federal Emergency Management Agency (FEMA) did not conduct a 2022 nationwide EAS test and has not yet scheduled a nationwide EAS test for 2023.  

The FCC’s rules, however, require EAS participants to annually review and update their identifying information for each station (e.g., transmitter location, EAS monitoring assignments, and make and model of EAS gear). 

The FCC and FEMA utilize ETRS to assess the reliability and effectiveness of the nation’s alert and warning infrastructure.

FCC Skips Key Steps with Proposed Cybersecurity Rules

The FCC should hold off on implementing its proposed new EAS cybersecurity rules for broadcasters until it has worked with equipment manufacturers to incorporate cybersecurity measures into the hardware and software they provide and explored using more secure alternatives to the public Internet.

That’s the gist of comments TAB filed the day before Christmas Eve, the deadline set by the FCC for its proposed new rulemaking in which the commission indicated that the most recent National EAS Test revealed a large number of EAS Participants were unable to receive and/or retransmit the test due to equipment failure and that 5,000 EAS Participants reported using outdated software or equipment that no longer supported regular software updates.  

Based on this, the FCC proposed that EAS Participants:

1. report any EAS equipment outage to the FCC and repair the equipment according to an ill-defined “reasonably prompt and diligent” performance standard; 
2. adopt cybersecurity plans covering “all communications systems and services” that might affect the ability to provide EAS alerts, including constantly monitoring the cybersecurity threat landscape and upgrading cybersecurity plans on an ongoing basis in response to new threats; and 
3. report to the FCC any unauthorized access to EAS equipment or any communications systems or services affecting the ability to provide EAS alerts within 72 hours of when the station knew or should have known of the unauthorized access.  

The comments, filed jointly with TAB’s counterparts across the country, also urged the FCC to work with EAS device manufacturers to incorporate features like:

1. modifications that automatically require password updates, 
2. integrated firewalls and multifactor authentication, and 
3. alerts for software patches and updates.  

The Joint Comments also argued that the FCC should retain the current rule that allows broadcasters to take broken EAS equipment out of operation for a period of 60 days without Commission notice or authorization, work with broadcasters to develop cybersecurity plans or incident reporting protocols rather than place that full burden on broadcasters without guidance on what the FCC will find satisfactory, and reject the punitive enforcement stance outlined in the NPRM. 

Questions? Contact TAB’s Michael Schneider or call (512) 322-9944.
 

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