Local public safety agencies and public safety groups have renewed their call for the FCC to require wireless carriers to support multimedia wireless emergency alerts (WEAs), and the Federal Emergency Management Agency and the National Weather Service are echoing their plea. Entities representing the deaf and hard of hearing say they also support multimedia alerts.

But the wireless industry says there are technical issues that still must be addressed before multimedia alerts can be formatted, and it stresses that alert originators can include links to such content in their messages.

Comments were filed by yesterday’s deadline in PS dockets 15-91 and 15-94 in response to a public notice released in March by the FCC’s Public Safety and Homeland Security Bureau seeking to refresh the agency’s record on how it can facilitate the delivery of multimedia content in WEAs (TR Daily, March 28).

In an order released in January requiring participating carriers to transmit alerts over more precise geographic areas, the FCC directed the Public Safety Bureau to release the public notice (TR Daily, Jan. 30).

Public safety entities have pressed the FCC to mandate multimedia alerts, while wireless industry entities have expressed concern about the potential for network congestion from such WEA upgrades.

In 2016, the FCC adopted a report and order that made changes to WEAs in an effort to make them more useful to public safety agencies and the public, including requirements that wireless carriers support embedded URLs and phone numbers in alerts (TR Daily, Sept. 29, 2016).

At the time, the Commission also adopted a further notice of proposed rulemaking with additional proposals, such as requiring carriers to support multimedia content in public safety messages. The FNPRM also sought views on necessary technical parameters and a compliance timeline.

In their comments filed in response to the public notice released in March, public safety entities said they still support an FCC mandate for multimedia WEAs. They said that such a capability will help save lives in disasters such as hurricanes, wildfires, and winter storms and when criminal suspects are being sought, and that it will help emergency managers reach people who don’t speak English, are blind, or are deaf or hard of hearing.

“Broadly speaking, the Commission should encourage participating service providers to upgrade WEA systems in a manner that eliminates disparities between what’s available to consumers and what’s available to WEA alert originators. Arguments that the WEA system was not designed for certain capabilities should have no bearing on whether to incorporate capabilities that already exist in wireless networks,” said the Association of Public-Safety Communications Officials-International. “When technology exists that could save lives, it should be used to save lives. Wireless carriers are in a position to improve public safety, and they should ensure that upgrades to their networks can be used in parallel to improve emergency alerts.”

“The requirement to support multimedia content in WEA should not be limited to Public Safety Messages, thumbnail-sized images and hazard symbols, or 4G LTE and future networks,” APCO added. “The assumption that the transmission of multimedia WEA messages would delay the receipt of time-sensitive alerts may not hold true, especially as wireless carriers continue to enhance their networks. Further, alert originators will be in the best position to judge whether the value added by multimedia content in a particular emergency outweighs any delay required for message composition and delivery. Thus, carriers should be required to transmit any type and quality of multimedia that an alert originator includes with any WEA message.”

In joint comments, Big City Emergency Managers, the National Emergency Management Association, and the International Association of Emergency Mangers said, “While the recently adopted rules are surely moving the system in the correct direction, the system continues to lack a number of critical capabilities; chief among them is the inability to include multimedia in alerts. Multimedia enhancements are a critical update that must be approved in order to support our mission to save lives and property.

“Similar to longer text messages, hyper-accurate geolocation, and the ability to share hyperlinks, multimedia is already something our phones and network can accommodate,” the groups noted. “The capability to share live news broadcasts and press conferences, to watching world events unfold in real time through tens of millions of photos, videos, and other graphics – this already occurs on a daily basis. Society is familiar with these features and expects them during emergencies. These powerful capabilities need to be integrated into the nation’s WEA system.”

“As the old adage goes, a picture is worth a thousand words. This could not be more relevant than supporting the emergency information needs of individuals with access and functional needs, including those with limited English proficiency,” the emergency managers continued. “For individuals who are deaf or hard of hearing, American Sign Language (ASL) is often used, but is a unique language that requires visual cues; English is truly their second language. For individuals who are blind or visually impaired large print or instructions given in an image (which can be zoomed in by the recipient) can be easier to understand. During an emergency, emergency managers are responsible for alerting their whole community and those members of our communities with disabilities, access, and functional needs deserve equal access to the information.”

“In this age of instant access to visual information via social media applications, we need to enhance our country’s ability to rapidly, efficiently and securely deliver comprehensive emergency information, including images, to the public. Pictures provide instant recognition and speak a universal language,” said the Harris County, Texas, Office of Homeland Security & Emergency Management. “Most importantly, they enable rapid response from every potential witness who could save countless lives through fast action. With the network upgrades to 5G, capacity for multimedia messages will be even greater, and we would be remiss not to advocate for multimedia capabilities for WEA to be in place as this upgrade occurs.”

Harris County added that it “continues to recover from Hurricane Harvey’s flooding impacts. The flooding during Harvey affected areas that had previously not flooded and creating unique challenges that were difficult to communicate. Had multimedia capabilities been available for WEA messages, inundation maps, traffic maps and infographics with protective measures could have been sent to residents, alerting them to hazards they may not have been familiar with.”

“Having a reference map for residents and visitors can mean the difference between action and non-action,” said the Los Angeles Emergency Management Department. “As an example of this [are] the recent brushfires that took place in the City of Los Angeles during 2017-18. Los Angeles needed the assistance of their residents and visitors to move them out of harm’s way and place them in evacuation centers and/or shelters and issued WEA messages. Because of the system’s limitations they were unable to include a map of the evacuation areas, only a reference for recipients to seek out this critical information via traditional media outlets. Less than half did.”

Multimedia alerts would also have been useful during winter storms in January, the city said.

The New York City Emergency Management Department said, “Despite the recent enhancements, significant gaps remain between what today’s technology can offer and what the WEA System supports. Chief among these gaps is the inability to incorporate multimedia (e.g., images, maps, infographics, etc.) into WEA messages. The need for this capability within the WEA System has been thoroughly documented in the public record beginning with proceedings of the Communications Security, Reliability, and Interoperability Council (‘CSRIC’) III in 2013, continuing with CSRIC IV, as well as by a multitude of other public safety and emergency management commenters.”

The city stressed what would have been the benefits of being able to send an alert with a picture after a 2016 bombing in the Chelsea neighborhood. “Early in the morning on September 19, 2016, our law enforcement partners had a suspect name, age, description, and photograph and asked for our Department’s help in eliciting the public’s assistance to locate the suspect. NYCEM transmitted a WEA message but, due to the system’s limitations, had to direct people to ‘see media for pic’ instead of being able to embed a photograph of the system. Following that WEA message, NYCEM contracted a research firm to conduct a poll of New Yorkers’ experience and behavior with the WEA message. While 100 percent of individuals polled received the WEA message, only 45 percent of recipients sought out the suspect’s photo from another source. If the suspect’s image was embedded in the WEA message, 100 percent of recipients would have seen the image.”

The Santa Barbara County, Calif., Office of Emergency Management cited recent “catastrophic wildfires, flooding and debris flows” that cost 23 lives and destroyed 529 structures. It said that “due to the flaws and technical limitations that currently plague WEA and EAS [Emergency Alert System], we cannot fully depend on them to deliver timely, accurate and targeted information to the public so that they can take steps to keep themselves safe.” Lack of multimedia content is one of the drawbacks of WEAs, it said.

The Policy Committee of the Regional Disaster Preparedness Organization in the Portland, Ore., area said, “Forthcoming improvements to provide targeted messaging, increase character count, provide a Spanish-language function, and test the system will increase WEA’s utility to local authorities. However, additional multimedia enhancements are still needed to ensure emergency warnings are correctly understood by the public – specifically the ability to send an image in a WEA message and provide alerts in languages other than English and Spanish.”

The Seattle Office of Emergency Management also urged the Commission “to act to meet the need for multimedia enhancements to WEA messages. Failure to do so leaves the City of Seattle susceptible to more potential disasters without the ability to properly alert our citizens. Failure to include these improvements to WEA is irresponsible to the citizens that we are charged to serve and protect. It will erode the trust of wireless alert originators to send a timely, informative message when life or death may be on the line.”

The District of Columbia Homeland Security and Emergency Management Agency said, “In this age of instant access to visual information via social media applications, we need to enhance our country’s ability to rapidly, efficiently and securely deliver comprehensive emergency information, including images, to the public. Pictures provide instant recognition and speak a universal language. Most importantly, they enable rapid response from every potential witness who could save countless lives through fast action. The Chelsea bombings in New York City highlighted this major weakness in the WEA system. Millions of residents who wanted to help find the suspect were given no other option but to take additional time to search for his photo. In any emergency, time is often a commodity we can’t afford to waste.”

“WEA needs to keep pace with advancements in wireless technology, mobile devices, and the evolving capabilities of alerting authorities. Incorporation of multimedia content in WEA is a next logical step toward saving lives with WEA,” said the National Weather Service.

“The FCC has been urged by multiple agencies to adopt rules for inclusion of an interactive map showing the recipient’s location along with the alert originator’s defined threat area.  Since 2007, NOAA’s NWS has made polygon-based alerts available to the public in graphical format.  Based on social science research conducted over the last 20 years, NOAA’s NWS reasserts that an interactive map is necessary to help people to better personalize the threat, so that those in harm’s way take decisive life-saving action,” the agency’s filing added.

“Once alert polygon vertices are broadcast to the device for ‘geo-fencing’ of alerts, as required by the Second Report And Order And Second Order On Reconsideration (January 30, 2018), those same vertices could be used to display the threat area on maps which are already built into the device (e.g. Google Maps, Apple Maps, etc.) or other map included as part of the WEA application.  Since the recipient’s location is also used in ‘geo-fencing’, it could be plotted on the map showing the recipient’s location relative to the threat area,” the National Weather Service added.

The filing requested “that social scientists be included as part of the effort to incorporate interactive maps in WEA.  Any maps associated with WEA should be clear and concise to ensure understanding by the public.” In addition, “WEA should take advantage and leverage the device’s built-in capabilities to render additional life-saving information in graphical, audio, or disability friendly formats,” according to the National Weather Service. “For example, short videos or other accessible content demonstrating protective action-taking (e.g. seek shelter, move to higher ground, etc.) could be built into the WEA application and rendered upon request by the recipient.”

“Despite assertions to the contrary in the telephone industry,” Digital Broadcasting Technologies LLC said, “there is technology available for deployment now to provide robust, multimedia capability in WEA messaging. DBT can today provide and transmit such multimedia WEA messaging with technology that it has developed.”

FEMA’s Integrated Public Alert & Warning System Program Office stressed that it’s “technically feasible to require multimedia content in WEA messages. Today, many Alert Originators include links to images, audio files, and web content in their Common Alerting Protocol (CAP) messages. … It would be a simple matter of updating the C-interface standards to allow the inclusion of these resources in the messages sent to the cell carriers for WEA distribution.” The IPAWS Program said it “enlisted the National Alliance for Public Safety GIS (NAPSG) to develop a set of simple symbols representing commonly used emergency message event codes. … The symbols are available as small picture files representing a Specific Area Message Encoding (SAME) event code intended to aid rapid recognition of an emergency message without the need for the viewer to be proficient in the English language.”

FEMA added, “The costs to include multimedia content in WEA messages is minimal on the part of public safety. They would need to add a procedure to create or obtain the content if they don’t already have one, but this is not thought to incur much if any cost to public safety.” It added that it “will continue to support testing with alert origination software companies and provide feedback and recommendations for desired functions for improved alert and warning through IPAWS. The benefit to public safety would be immense.” FEMA echoed the points made by local and other public safety entities about the benefits of multimedia alerts to “people with access and functional needs” and “people with limited English proficiency” as well as the advantage of “[v]isually presenting evacuation routes, hazard areas, or storm tracks instead of describing via text[.]”

“Enabling multimedia content in WEA messages is critical to the public safety protection of the deaf and hard of hearing community,” said a filing by a number of consumer groups for the deaf and hard of hearing and two other entities.

The filing was submitted by Telecommunications for the Deaf and Hard of Hearing, Inc., the National Association of the Deaf, the Hearing Loss Association of America, the Deaf and Hard of Hearing Consumer Advocacy Network, the Association of Late-Deafened Adults, Inc., the Cerebral Palsy and Deaf Organization, the California Coalition of Agencies Serving the Deaf and Hard of Hearing, and the Gallaudet University Rehabilitation Engineering Research Center on Technology for the Deaf and Hard of Hearing. “If network costs are prohibitive or if this step would substantially add to the congestion of the networks,” the entities said, they “encourage carriers to come forward with specific documentation for review and a discussion of potential solutions by all stakeholders.”

But CTIA stressed that “technical and operational limitations” remain to enabling multimedia alerts.

“Most relevant to the Commission’s WEA Multimedia Public Notice, the Commission now requires Participating Commercial Mobile Service (CMS) Providers to support the transmission of embedded Uniform Resource Locators (URLs) and phone numbers in WEA Alert Messages. In adopting the embedded URL requirements, the Commission noted that this upgrade ‘will dramatically improve WEA’s effectiveness’ and highlighted that ‘the public safety community views this change as the most important among all those we consider in this proceeding. . . .’ Thus, through embedded URLs available today, alert originators can ‘transform the scope of WEA from a character-limited text message service to a multimedia-enabled, comprehensive disaster response resource,’ in order to provide information to spur the public to action during an emergency,” CTIA said.

“With regard to embedding multimedia content within a WEA message, however, CTIA and its member companies encourage the Commission to recognize the significant technical and operational limitations – both with wireless networks and WEA-capable devices – that would be very challenging to overcome within the WEA system,” the trade group added. “As explained in these comments, the WEA system was intentionally designed to transmit only very small amounts of text data to ensure the timely delivery of WEA messages to millions of wireless consumers.”

CTIA added, “Nonetheless, CTIA and its member companies look forward to discussing these issues with the alert originator community and working collaboratively to evaluate ways that mobile wireless technologies can further enhance the WEA system to meet the evolving public safety mission. By focusing on reasonable and practical methods for designing, implementing, and enhancing the voluntary WEA system and allowing the time for standards-based technology to be developed, tested, and implemented, the Commission can maintain the important role of the WEA system to the safety and security of America’s wireless consumers.”

“Technical experts must evaluate whether increasing the number of segments available for WEA text data to support transmitting non-text content would overwhelm the limited resources available to the control channel,” CTIA added. “Using the control channel beyond its intended purpose could pose a significant risk that critical system information may not be available to mobile devices, which could impact the ability of consumers to respond to an emergency. Notably, the greatest risk is the potential for a denial-of-service event during an emergency, which could occur due to overloading of the network’s shared control channel resources. However, even before further technical evaluation to address these issues, there are critical policy issues and tradeoffs that require further discussion and evaluation.”

CTIA continued that “to maintain the operation of the LTE network, Cell Broadcast best practices require that the broadcast message be kept to a reasonable size to ensure that other broadcast messages (used to control the LTE network) are delivered – otherwise, the overall LTE network may not function properly, as discussed above. From a technical perspective, the existing WEA system would require a fundamental change to the Cell Broadcast standard to adequately manage even small non-text content (even if those file sizes were limited to 5 to 10 kB). Thus, a global standards effort would be necessary to maintain global interoperability and roaming.

“On the network side of the WEA platform, the LTE standardized delivery method transmits with a set delay between each segment of a message. These delays are pre-configured into mobile base stations and can range from 80 milliseconds to 5.12 seconds, with each operator specifying the value on their network based on engineering and operational considerations,” CTIA said. “Thus, assuming current transmission delays, a 5 kB image (that requires 17 segments) could take from 1.28 to 82 seconds to be delivered, while a 10 kB image (that requires 34 segments) could take from 2.56 to 164 seconds.”

“Separately, the Commission has suggested that there may be an opportunity to allow for multimedia within WEA messages through the use of evolved Multimedia Broadcast Multicast Service (eMBMS), which is part of the 3GPP standards supporting LTE. However, the ability of eMBMS to support WEA messages remains unclear, if not unlikely for the foreseeable future,” CTIA said. “Unlike WEA’s near-ubiquitous availability, eMBMS functionality has been very limited to ‘hot spots’ with dense capacity needs for video.”

The trade group also said that “further exploration and discussion is necessary to determine whether 5G could enable the delivery of multimedia within WEA messages beyond the use of embedded links. CTIA and its members companies look forward to reviewing the record, the forthcoming report from CSRIC VI Working Group 2 – Comprehensive Re-Imagining of Emergency Alerting, and engaging in discussions with the alert originator community to determine how WEA can be further enhanced.”

The Alliance for Telecommunications Industry Solutions, on behalf of its Wireless Technologies and Systems Committee, also noted “that the Commission’s existing rules permit the transmission of multimedia content in WEA messages via embedded Uniform Resource Locators (URLs), effective just late last year. ATIS remains concerned with the congestion-related impacts of such embedded URLs as alert originators increase their use of them and more handsets incorporate the capability. However, the use of URLs with appropriate best practices (e.g. well-designed website links) is the only effective means of providing multimedia in WEA today and it would be appropriate to allow stakeholders additional experience with these new capabilities, particularly after 360-character alerts become available to enable alert originators to provide more descriptive text WEAs.

“ATIS therefore continues to prefer the use of embedded URLs, which allow the provision of up to date multimedia capabilities without the need to modify/upgrade WEA-specific multimedia capabilities whenever new multimedia features are added,” it added. “ATIS WTSC notes that there remain technical constraints associated with the transmission of multimedia content in WEA messages outside of embedded URLs. As ATIS has previously noted, the Cell Broadcast Service (CBS) over-the-air interface that is used to transmit WEA messages, is not designed for the transmission of multimedia content.”

“Multimedia in WEA messages also will have implications for meeting character limits,” ATIS said. “In responding to the Commission’s September 2016 Further NPRM seeking comment on an appropriate maximum size for any WEA multimedia content, ATIS noted that even a relatively small multimedia file would still be too large to transmit in WEA as it would require multiple WEA binary 360-character messages. As explained in the Feasibility Study for WEA Supplemental Text, the use of significant numbers of WEA messages to transmit multimedia alerts that require more than 360 characters has potential for disruption of the network.

“ATIS also does not believe that staggering the transmission of multimedia WEA message segments would mitigate potential network congestion concerns and facilitate delivery of this content,” the filing added. “As ATIS has said previously, the staggering of multimedia message segments will negatively impact the timely delivery of the complete message. The technical feasibility of such an approach would also require additional study within standards organizations.”

ATIS also recommended “that the Commission carefully consider, and allow the industry to develop approaches to mitigate, possible cybersecurity challenges associated with the transmission of multimedia content before any new multimedia requirements could be implemented. ATIS further notes that the previously-identified challenges associated with Evolved Multimedia Broadcast Multicast Service in LTE (eMBMS) remain. Unlike CBS, which was not designed for the transmission of multimedia content, eMBMS could, in theory, permit the broadcasting of multimedia content. However, while CBS is ubiquitously deployed, it should be noted that the market for eMBMS has not developed at least in part due to its complexity. Significant technical work also remains in order to be able to utilize eMBMS for WEA, as eMBMS was originally designed for linear programming multimedia (e.g., television or movie presentations).”

ATIS also said “there are approximately 25 industry standards that would need to be developed or modified, including impacts to WEA standards efforts in progress from previous Commission rule changes (including the Commission’s September 2016 Report and Order and November 2017 Order on Reconsideration). Additional work to develop technologies and implement any new multimedia requirements would complicate these ongoing efforts across the ecosystem, from alert originators to service providers to device manufacturers, be counterproductive and could slow the industry’s work.”

“The Commission last sought comment on incorporating multimedia capability into WEA alert messages in 2016. Since that time, despite technological advancements and standards work, incorporating multimedia content into WEA sent using proven cell broadcast technology still presents significant challenges,” AT&T, Inc., said. “AT&T urges the Commission to refrain from requiring multimedia content in WEA messages until solutions are identified and standardized.

“In the meantime, the Commission should urge alert originators to leverage embedded references in WEA messages — such as URLs, a capability already available — as a means for delivering multimedia content,” AT&T added. “URLs may be used to direct WEA recipients to appropriate sources of further information, such as web pages containing rich multimedia content, as well as broadcast radio and television. This approach would reduce or eliminate many concerns including backwards compatibility, interoperability/roaming, and ubiquity raised by multimedia messages. AT&T further encourages the Commission to remain technology neutral on all WEA requirements to afford industry the flexibility to take advantage of new capabilities and advances to meet any future requirements.”

The National Center for Missing & Exploited Children said that 924 abducted children have been recovered due to Amber Alerts. “When considering the technical feasibility of incorporating multimedia content into WEA messages it is important to ensure the delivery of messages to recipients remains reliable and error-free,” it said. “The Commission’s rule requiring participating CMS Providers to support embedded references should allow users who wish to interact and obtain information beyond the recently-expanded limitations of a WEA AMBER Alert message, to seek out further relevant details (e.g., images or abduction circumstances).”- Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily