FCC Filing: Amendment of Part 11 of the Commission’s Rules Regarding the Emergency Alert System

EMERGENCY COMMUNICATIONS

PS 15-91   — Wireless Emergency Alerts
PS 15-94   — Emergency Alert System

COMMENTS

TDI and the tagged consumer groups filed comments to the Federal Communications Commission about its notice of proposed rulemaking on its improvements of the Wireless Emergency Alert System (WEA) and the Emergency Alert System (EAS).

[see below, under Tags: for the full list of signatories]

TDI supported the Commission’s actions in this proceeding and provided these comments to recommend steps the Commission can take to ensure that the WEA and EAS are accessible to all Americans, including consumers with disabilities. 

We supported the Commission’s proposal to rename WEA’s “Presidential Alert” class of alert messages to “National Alert” and to include alerts from the Administrator of the Federal Emergency Management Agency (“FEMA”) within the National Alert category. We recognized FEMA’s efforts to reach out to Deaf and hard-of-hearing communities with additional interpreting support. However, many people from these communities were left out from the emergency alerting process or experience communication issues.

In fact, according to preliminary research performed by TDI, approximately 45% of deaf and hard-of-hearing individuals are unaware of WEAs. Moreover, 69% are unsure of whether they have WEA capability on their smartphones. Thus, TDI believes that designating National Alerts as a non-optional category of alerts would be the best way to include these communities to be aware of what is happening in their areas.

Additionally, we urged the Commission to require that all National Alerts (including Presidential and FEMA alerts) include a link to a website where individuals can access more information about the subject alert. Such information should be made available (at a minimum) in ASL and other languages.

In addition, we believe that State Emergency Communications Committees (SECC) should consult with representatives from the Deaf and Hard of Hearing Communities. The Commission should have each chief executive from each state set up these committees to review the composition and governance of the SECC.

Also, the State EAS Plans should ensure communication accessibility for consumers with disabilities. In one specific section, it mentions they should ensure timely communication access used by non-speaking English populations, however, we were not sure if deaf and hard of hearing communities are included in that category. Therefore, we require the EAS alert content to be provided in ASL as well as written in plain language easy to understand. Simple messages are needed to elicit appropriate responses from individuals affected by the disaster including people with limited English comprehension.

We saw that according to TDI’s research, approximately 4% of the deaf and hard of hearing population do not have wireless devices and therefore lack access to WEAs. We requested making Emergency Alerts accessible for consumers with disabilities. The Commission should also ensure that emergency alerts can reach and be displayed on electronic traffic billboards as well as electronic signage at train and airport terminals.

URL below is linked to the actual filing document on FCC’s Electronic Comment Filing System 

https://ecfsapi.fcc.gov/file/104211772717963/TDI%20et%20al%20WEA-EAS%20NPRM%20Comments%20(4-20-2021).pdf