EMWIN Downlink Frequencies Under Attack By Broadband Interests

IMPORTANT NEWS FOR EMWIN USERS

[Keep checking back here as I'm constantly adding links and information.]

NOTE! While the deadline for response comments was on Monday the 28th, the ARRL advises that the FCC is pretty good about still taking comments filed after. So if you still think you'd like to file one, go ahead and give it a try. Couldn't hurt.

For those SKYWARN spotter and ARES/RACES groups across the US which make use of EMWIN to distribute weather bulletins to their spotters, hams, and to their local communities, some kinda scary news...

THE PROBLEM

From the EMWIN-Users listgroup: "Of special interest to EMWIN users and vendors is FCC Public Notice DA-1035 (ET Docket No. 10-123) released on June 4, 2010 calling for public comment on the extent and manner of use of the 1675-1710 MHz frequency band by non-federal users."

The FCC is calling for comments on the feasibility of the idea to reallocate/take the current frequencies now used for EMWIN downlink, as well as other services such as GVAR and LRIT, with broadband (cellular) services, which could interfere with (or cease) downlink of these services for many users across the country and other parts of the world...including the EMWIN downlinks that many Emergency Management Agencies now enjoy across the nation and even abroad. Problem is, they've only given us until the 28th to respond...of THIS month. That's right. We have just DAYS to find every possible example of EMWIN use across this country and abroad - and to have each and every one of them respond and make us look legitimitely important. Do you know how to get hundreds of Emergency Management and Civil Defense Agencies - who apparently don't even at this time know that this is even happening much less that they are supposed to defend themselves - to suddenly up and grab muskets and defend the use of their EMWIN systems with comments? But wait! FEDERAL interests aren't allowed to respond to this particular FCC Docket. They have to file using some other docket. I'm trying to find out exactly how they're supposed to file, and where online we can view their own responses if they exist.

EMAs and CD agencies use EMWIN to get weather and emergency information SIMULTANEOUSLY with their NWS kin. The EMWIN data downloaded directly from the GOES satellites is received and redistributed IMMEDIATELY - on the order of a whole two MINUTES faster than the NWR weather radio system does. In severe weather and emergency situations, two minutes is a LOT and allows Emergency Managers and CD agents that much more time to decide what to do. That can save lives.

In the Pacific, and even recently in Haiti where our government just GIFTED an EMWIN ground station, EMWIN is the only source of hurricane and other emergency-related information. They have nothing else.

There are many places around the country that don't HAVE cable or DSL. In these places, EMWIN is much appreciated.

Sharing with broadband could introduce interference problems which could mean loss of transmitted data and the thought that the FCC might even consider this acceptable is kind of ludicrous. What are they thinking?

There's the thought by the broadband interests that EMWIN could be distributed by other means, such as over the Internet. I disagree with this, however. The whole reason EMWIN was originally created was to give Emergency Management Agencies and Civil Defense agencies a means with which to receive the latest weather data as early as possible to give the fastest possible reaction time. Forcing redistribution through the internet is just non-feasible. It introduces likelihoods for serious delays. The more servers you have between the satellite and the end user the more liklihood for breakdowns, downtimes, susceptibility to things like hackings and DOS attacks, or delays from just plain traffic overload. Weather data distributed via the internet could introduce unacceptable delays from hours to days, which would make EMWIN data non-feasible any longer as an Emergency Management tool, a Civil Defense tool, or anything more than a notification method of "convenience" and "curiosity" than anything that could be used to help save lives by giving the fastest possible notification times. Internet distributuion would introduce some of the SLOWEST POSSIBLE notification times.

I realize the broadband people have a dream and they'd like to see it come to fruition; but I don't think we need to knock out all of the greatest ideas that mankind has ever come up with and just abandon them to make room for someone's GUESS that broadband will be the next new saviour of the world.

EMWIN has been around for many many years, and it is not the same itty-bitty thing that it started out as. It has improved greatly, adding more bulletins, more useful graphics, and we were right in the middle of a transition to even FASTER downlink speeds when the broadband companies came along with THIS stupidity.

EMWIN doesn't just offer weather bulletins. It offers civil emergency-related bulletins such as warnings for hazards such as earthquakes, tsunamis, avalanches, road hazards, hazardous materials accidents, telephone outages, law enforcement emergencies, nuclear hazards, national attack warnings, etc. It offers varioius graphics, too, such as satellite and radar and forecast plots.

The EMWIN system costs little to set up and maintain. The software is cheap and can do many awesome things - including starting other programs on issuance of a watch or warning, or setting off external equipment such as flashers or sirens using X10 capability. It's exceptionally portable and quick to set up, making it incredibly useful as an emergency tool.

Some towns across the US actually depend on te EMWIN downlink to set off their sirens during weather emergencies...and broadband people want to turn OFF the downlink that sets them off.

Here is an email from the EMWIN Staff, sent to the EMWIN-Users listgroup.

The FCC Public Notice can be had in both MS Word and PDF formats.
IMPORTANT! Use the FCC Notice's guidelines to also respond with your comments! There are NINE questions to answer in the FCC Notice. Please do your best to answer them! (Number 1 doesn't seem to apply to most of us, so you can simply answer that one with "Doesn't Apply" or "N/A".)

WHAT CAN WE DO?

We need to write our comments to the FCC, and meanwhile get as many other people and orgainzations and agencies to respond as possible. Harp on our numbers - how many of us are actually using the downlink; and on the SPEED with which EMWIN allows us to receive the bulletins - on par with our NWS counterparts, often on the order of minutes before they actually go out over the NWR or are received using internet-based commercial resources. Mention how EMWIN is used in your area. Be specific.

Don't let apathy in. Don't GUESS at how this battle will go and assume that there's gonna be a last-minute cavalry rescue by someone in government who "has to know" and who will take care of the problem for us. That may or may not happen. More I ask around, more it seems NOBODY KNOWS about this in government circles!

1. Make your comments! You can mail them in, or you can make them online using the Internet by accessing the ECFS: http://fjallfoss.fcc.gov/ecfs2/ or the Federal eRulemaking Portal: http://www.regulations.gov. Don't just click these links first, though. READ THE FCC PUBLIC NOTICE AND ADHERE TO THEIR GUIDELINES! NOTE: These things MUST be composed in a certain WAY, people, or they won't consider them. So please try to compose these documents in the manner that they describe.
   
2. Write, email, and/or visit your local Senators and Representatives. Danny Lloyd's blog site (People To Write Concerning FCC Docket 10-123) lists how you can do this.
   
3. Contact the Press,too. If you use EMWIN user (are you an emergency manager? EMWIN sysop or manager? end user of EMWIN who receives bulletins FROM the system? does your University make use of it? your TV station?), let THEM know that we could be losing the EMWIN downlinks. Why not. Couldn't hurt. What's the worst that could happen? Go for it. The more local people who contact their local Press asking them to do a story, the more interested they'll note that people are, and the more likely they'll be to do a story. Contact TV stations, and newspapers big AND small. Tell them how you've been using EMWIN and what good it has done for you. Emphasize it's importance in your community. Hit the NATIONAL networks, too! ABC, CBS, NBC, CNN, MSNBC, Headline News, etc. Again, more we request air time, more likely they will. HIT em!
   
4. Contact OTHER listgroups such as:
   THE RISKS DIGEST - Forum On Risks To The Public In Computers And Related Systems
   List people can contact more people, and those people can contact more people, and so on, and so on, and so on... Personally, I've been duping to AC-SKYWARN, GeorgiaSKYWARN, JAXSKYWARN, and PC-SKYWARN, for some examples.
   
5. Join listgroups like EMWIN-Users, and WxMesg to keep yourself abreast of the latest.

If you're an ARRL member:

1. Email your Section Managers so that they know what is going on. THIS IS IMPORTANT. They can spread the word down into their own sections.

Some other links on the subject:

• NOAA/NWS EMWIN Home Page
  
• National Broadband Plan - How the broadband companies see the world.
  
• What'sUpWithThat.com (Colorado State University article) - NOAA/GOES Satellite Communications At Risk Due To Proposed Frequency Spectrum Auction. This site gives excellent description of the problem, and how vastly the auction affects things. Use this to educate yourself.
  
• Potential L-band Frequency Sharing - from NOAA-EMWIN Page
  
• NOAA Public Information Statement (PNS) Regarding - NOAA - Note that the actual FCC Notice is using the word "reallocating", while NWS/NOAA keeps using the word "sharing". This is confusing people.
  
• ARRLweb Article - FCC Issues Public Notice to Seek Information, Comments on Current Use of 1675-1710 MHz (June 14, 2010)
  
• View Current Responses to ET 10-123 (For "Proceding Number" you want to enter "10-123".)
  
  • Example Response: Alachua County SKYWARN
    [HTML] [Word doc] - Rough draft of Alachua County SKYWARN response (Consider this like a "rough draft". The actual document is still under construction and has not been sent, just yet. I'm still working on it. But hopefully others will still find it of some use as a template for composing their own comments.)
• People To Write Concerning FCC Docket 10-123 - Please carbon copy any correspondance with the Department of Commerce, NOAA or NWS to your Senator and Representive. Because of the short time span, you will want to consider also calling your Senator and Representative.
  
• StormReady Guidelines - You will notice that EMWIN is the second item listed, with a recommendation to use a satellite dish. The EMWIN service is such a value that it is listed right after NOAA Weather Radio.
  
• Emergency Management Broadcasting Frequencies - courtesy Zephyrus Electronics, Inc. - This could possibly be used as a starting point to show widespread use of EMWIN across the United States. Could also be used as a contact list to notify these groups of the EMWIN issue and to cooperate and put in their own comments - even if they're no longer "retransmitting", but still use EMWIN for other things. I count some 62 sites in here!

We've been given LESS THAN THREE WEEKS to compose comments and submit them to the FCC. That's kinda ridiculous, but there it is. So let's move on this. Spread the word fast. Compose away people. Join lists such as EMWIN-Users, EMWIN Broadcasters, and WxMesg, too, for more information, and for ideas and suggestions on what to mention in your comments.

UPDATE - 06/11/10: Got word ARRL is actually researching to make their own response, but they've got a couple of ham-related frequency fights going on that they want to handle, first. As well, NOAA finally issued a PNS bulletin this afternoon acknowledging the EMWIN problem and advised that they too will be submitting a response.

UPDATE - 06/16/10: Bigger guns taking notice? Noting hits from the following pages to this blog over the past week: ARRL, Naval Oceans Systems Command.

36 comments now submitted to the FCC, up 21 from Friday. Keep it up, people!

Email from Colin Schulz, Pacific Island Meteorological Services. Chris is composing a response, and also making effort to bring other Pacific Island interests on-board.

Noticing many of the filed comments are one-liners and single paragraph entries without any contact information, or information about what locality the comment applies to, of for which organization or agency the individual is associated with. At same time, none of the nine questions requested answered in the FCC Notice are answered. This is worrisome. People not paying attention. Will the FCC take these into consideration? or throw them out instead? I don't think there's an online way to re-submit, either. :( University responses are much-better composed...especially Colorado State, FSU, etc.

UPDATE: 06/17/2010: Email from David Sumner, ARRL. ARRL not sure of ham interest level. Therefore, doesn't know how to make comments.

PRESS ATTENTION:

I think I'll list any kind of Press attention to the matter here.

• WVOA / WOUA - University of Alabama
• Ham Radio Daily (ARRL News)

INTERESTING OBSERVATIONS

• Sudden odd behavior on the part of NWS employees. Emails to NWS (especially EMWIN-related-) employees with questions having anything to do with the EMWIN issue go unanswered. This is highly unusual considering that the employees emailed NEVER ignore an email and are ALWAYS otherwise VERY helpful and anxious to respond. This would seem to indicate that there is some sort of a gag order is in place. Should we contemplate requesting FOIA copies of any internal memoes so ordering employees to keep quiet?
  
• NOAA Public Notice (PNSWSH) put out on the 11th uses the word "sharing", while the FCC Notice uses the word "reallocate". This is confusing. Personally, I'm going with the FCC Notice's verbiage.

Last Updated: June 17, 2010, 11:26am