February 7, 2018 – The Wireless RERC submitted Ex Parte comments replying to the FCC’s Hurricane Response Public Notice [PS Docket # 17-344]. The Public Notice sought input on the effectiveness of emergency communications technologies, procedures, and policies that were employed in response to hurricanes Harvey, Irma, Maria, and Nate and “additional information relevant to the 2017 hurricane season’s impact on communications generally.[i]” The Wireless RERC’s comments were submitted as near-future considerations for remediating communications access issues. The intent was to supply unbiased considerations to help ensure that individuals with disabilities and other populations disproportionately impacted by disasters have alternative and accessible means to receive emergency information when cell coverage is disrupted, and access to power is limited. The Wireless RERC initially addressed this topic in 2013, after several years of severe tornado season damage. We remain convinced that the FM chip capability holds great promise as a public safety application and agree with FCC Chairman Pai’s assessment that “Access to reliable communications services during times of emergency is critical.[ii]” Two documents were included in the submission, a short 2-page brief and a longer research brief elucidating the benefits of FM Radio chip activation for emergency response. The submission elaborates on the following three points:
- The Integrated Public Alert and Warning System(IPAWS) was created to reach the public during times of emergency using as many “communications pathways as practicable.”[iii] FM radio on mobile devices is a possible and pragmatic pathway that is not currently being utilized.
- A synergistic relationship between the traditional broadcast industry and the wireless industry could remedy emergency alert and information access concerns held by providers (network congestion), emergency managers (timeliness of message), and by citizens (full access in the most expedient modality).
- Americans living with disabilities are at greater risk of injury and harm during an emergency because the means of attaining information may not be conveyed in a way by which they can discern. A drastic reduction in the number of deaths and injuries could occur if proper communication coupled with accurate forecasting were implemented. We estimated $33 million of related medical expenses over the past ten years could have been avoided.[iv]
[i] FCC. (2017). Hurricane Response Public Notice [PS Docket # 17-344]. Retrieved from https://apps.fcc.gov/edocs_public/attachmatch/DA-17-1180A1.pdf
[iii] FEMA. (2010). Strategic plan for the integrated public alert and warning system (IPAWS) program. Retrieved from https://www.fema.gov/pdf/emergency/ipaws/ipaws_strategic_plan.pdf
[iv] The estimate is based on NWS statistics concerning injuries and fatalities as a result of weather events and extant research on the average costs of emergency room visits.