RICE-NESHAP Regulations Apply to Broadcasters

By Mike Hendrickson, CPBE, CBNT

Are you familiar with the term RICE-NESHAP? You may have seen it in what you considered an annoying notice from a meaningless agency because you only have an “emergency” generator. If that was what you thought, you need to think again!
RICE-NESHAP is an acronym that translates to Reciprocating Internal Combustion Engine and National Emissions Standards for Hazardous Air Pollutants. In the context of the EPA rules it applies to any stationary internal combustion engine, whether an emergency generator, or a pump engine or other device powered by a stationary internal combustion engine.

The EPA first introduced these rules for engines in June 2004 and adopted the final rules in January 2013. If you have a stationary engine in use – emergency generator or not – you need to know these rules. Failure to comply can mean a fine for the engine owner.

First, understand that the EPA rules are the minimum requirements. There may be state, county, and local requirements that may be more stringent. Also, many of these agencies are much more aggressive with their enforcement than the federal EPA.
To know what federal, state, county, or local rules may apply, collect the following information: The date of manufacture or reconstruction (as defined by CFR title 40, part 63.2), the type of engine (spark ignition (SI) or compression ignition (SI), the size of the engine in brake horsepower, and any manufacturer certifications.

The rules contain regulations regarding record keeping. At a minimum you will need to keep track of the use of the engine and the maintenance it receives. The rules also specify limitations on the number of hours per year the engine may be run in non-emergency use or testing. Non-emergency use includes the use of the generator in load-shed programs.

I encourage every engineer with an emergency generator to become familiar with the rules. The specific rules are located at CFR title 40, part 63, subpart ZZZZ.

Online Resouces

SBE EAS Advisory Group Publishes EAS Security Notes

Prepared by the SBE EAS Advisory Group

Intrusions into computerized equipment have been around since the internet became a reality years ago. It is no surprise to broadcast engineers that these invasions have made their way into radio and television stations.

Most recently, EAS devices have been a major target. To comply with FCC rules, these devices must have internet access to receive information from FEMA via IPAWS.

Security for EAS and other station devices should be a high priority for station engineers. As a result, the SBE EAS Advisory group has put together a basic security guidelines summary to aid stations in assuring that all equipment is protected from these outside intrusions.

Summary

Every week, broadcasters like you are having their station equipment and computers hacked or tampered with by outsiders or malware infections that affect station computers and networks. If it hasn’t happened to you yet, the odds are unfortunately high that it eventually will happen.

These types of intrusions are more than an inconvenience. It can cost you to repair the systems that were compromised. It can cost you revenue for lost airtime. It can cost you credibility in your audience and community. Moreover, it eventually will cost all of us if the government feels it necessary to step in with additional regulations and requirements on broadcasters.

At the same time, it’s challenging for many broadcasters to keep up with the wide range of potential cyberattacks. Many broadcasters don’t know they have become vulnerable to attackers until it’s too late.
To help broadcasters address this growing concern, we have compiled some tips and best practices on how to keep your operation from falling prey to cybercrime. The bottom line:
• Know your Systems. Know what is connected to the network and the internet: at the office, studio, transmitter site, and remotes. If it’s connected, it is at risk.
• Defend your Network. Anything that is connected to your network or the internet must be behind a firewall.
• Protect your Equipment. Change default passwords. Change default usernames. Regularly check for and install any software upgrades or patches for equipment.
• Use Common Sense with Email and the Internet. Be cautious about opening email attachments or downloading from websites you don’t completely trust. Harmful malware can enter your station, and do significant damage to your business.
What is the problem?

Recent events had plainly shown that broadcasters are a low-hanging fruit for internet mischief-makers and cybercriminals. All too frequently, this involves key station equipment and computers left vulnerable to the internet, not changing default passwords, or even not having passwords at all.

The results have included the entire programming stream disrupted by IP streamers redirected to offensive, political and/or obscene content, the issuance of false or simulated EAS messages, the creation of fake messages and alerts via RDS encoders, the wholesale disruption of station operations when computers are locked via malware and viruses, and more. These are issues that have already happened, repeatedly.

In many cases, the threats boil down to simple vulnerabilities that could have been easily addressed beforehand.
• Stations with unconfigured firewalls – or even no firewalls.
• Station equipment left exposed and unprotected to the open internet.
• Station equipment left with default or easily guessable passwords – or even no passwords.
• Email attachments open, which introduced malware across the station network.

Presenting the potential for reaching a wide audience with inappropriate or political content, broadcasters present an irresistible opportunity for internet bad guys. Some broadcasters have opined that cybersecurity is too expensive or difficult. However, as we outline below, broadcasters can take preventative steps that are often a minimal expense – or no expense at all.

The technical solutions:

• Know Your Systems. Know what systems are connected to your network and to the internet, and know which systems should not be. If it is connected to the network, it’s going to need to be protected. This applies to looking at your systems throughout your operation. This includes the business office, studios, transmitter sites, remote control points, and other remote sites.
• Firewalls to Defend Your Network. The one security item every company needs is a firewall, a security appliance that attaches to your network and acts as the protective shield between the outside world and your wired and/or wireless network. A firewall continuously inspects traffic and matches it against a set of predesigned rules. If the traffic qualifies as safe, it’s allowed onto your network. If the traffic is questionable, the firewall blocks it and stops an attack before it enters your network. Just about anything in your broadcast facility should be behind a firewall if it is on your network, or going to be connected to the internet. Properly configure your firewall, make sure any software or firmware is up to date, and don’t leave ports open.
• Equipment Passwords and Account Management. Equipment in your station may come with a default password. You are urged to change default passwords on any equipment in your operation. If there are accounts or usernames on equipment that are default, or unused, you should also change or delete these. And remember, just because a system has a password, does not mean that it may be fully protected from access by other means. Equipment needs to be behind a firewall.
• Updates and Patches. The manufacturers of equipment in your station may contact you periodically regarding software patches and updates. Make it a practice of applying those software updates in a timely manner. Also, make it a practice of checking with your various manufacturers from time to time to see if they have released software updates of which you may not have been. These updates and patches may include not only feature improvements and bug fixes; they may also contain critical security patches.
• Secure Networks. Other measures to consider is a virtual private network (VPN). A VPN securely and inexpensively uses the public internet, instead of privately owned or leased lines, to provide remote sites and individuals with secure access to your organization’s network. Consider, for example, a VPN link as part of the STL, if that relies on an IP stream from the studio to transmitter.
• Safe Web Browsing and E-Mail Habits. Very bad things can enter the station via email or suspect web sites. If your station’s employees send e-mails and browse the internet (and of course, virtually all do!), you may also want to consider a software security solutions that include e-mail security, Web gateway security, and URL filtering.
The social solutions

• Security fundamentally involves a social aspect. Internally, you may need to reorient your employees and colleagues around safe email and web browsing habits. You may want to orient these employees to be wary of scam and phishing emails, and to beware of potentially dangerous attachments to emails from unknown or suspicious senders. You may need to reinforce safe web browsing habits, such as being careful not to download content from unknown or suspect websites.
• Broadcasters are a community. Externally, you may find opportunities to share information about what you are doing to improve security, what threats you see, and how you are addressing them.
When to call in an IT security consultant

There are going to be things you might not be able to do alone as a broadcaster. For FCC issues, you get outside legal advice. For annual and quarterly financials, you have an accountant. The same goes for security expertise. When you need to conduct a risk assessment, or get assistance in setting up network and IT security solutions, it may be money well spent it if you don’t have the expertise to do it yourself.

Don’t be part of the problem. Be part of the solution.

The Society of Broadcast Engineers Forms EAS Advisory Group

The Society of Broadcast Engineers has actively worked as a source of information for the Emergency Alert System since it was launched. As the system has developed and evolved to include new technologies and alerting partners, so has the SBE adapted to be the most effective and thorough resource for broadcasters to use to implement their EAS efforts.

As part of this evolution, SBE President Jerry Massey, CPBE, 8-VSB, AMD, DRB, CBNT, authorized the formation of the SBE EAS Advisory Group. The purpose of the group is to stay abreast of developments regarding EAS that will affect SBE members, including changes in federal regulations, policy and technology, and communicate pertinent developments to appropriate SBE national leadership and staff.

The group’s member’s are:
Larry Wilkins, CPBE, AMD, CBNT (group chair)
George Molnar
James Hoge
Ed Czarnecki (Monroe Electronics/Digital Alert Systems)
Harold Price (Sage Alerting Systems)

The group members were chosen to yield insight from the two SBE national committees that are involved with EAS issues, SBE members who are heavily involved with EAS, and SBE sustaining members that manufacture EAS equipment. The group reports to Wayne Pecena, CPBE, 8-VSB, AMD, DRB, CBNE, the chair of the SBE Education Committee, and Joe Snelson, CPBE, 8-VSB, the chair of the SBE Government Relations Committee.

On the announcement of the group’s formation, SBE President Jerry Massey said, “The SBE has worked with the various EAS partners, from stations to manufacturers to legislators, to be the trusted source of EAS information. The SBE EAS Advisory Group continues the effort that was begun by previous SBE committees.”

Larry Wilkins, the group chair, added, “Going forward, one focus of the group will be to field reports concerning origination or distribution problems from broadcast stations and state emergency communications committees (SECC). Using the expertise of the committee members along with information from our contacts with the FCC and FEMA, a recommended solution can be issued to the industry.”

Initial Findings of the 2016 EAS Nationwide Test

EAS logoAt the end of December, the FCC released an initial overview of the nationwide EAS test results and highlighted several opportunities for strengthening the EAS. The Federal Emergency Management Agency (FEMA), in coordination with the Federal Communications Commission (Commission) and the National Weather Service (NWS), conducted a nationwide test of the Emergency Alert System (EAS) at 2:20 p.m. EDT on Sept. 28, 2016. The nationwide test was designed to assess the reliability and effectiveness of the EAS, with a particular emphasis on testing FEMA’s Integrated Public Alert and Warning System (IPAWS), the integrated gateway through which common alerting protocol-based (CAP-based) EAS alerts are disseminated to EAS Participants.

The test also provided the Commission an opportunity to evaluate improvements made to the EAS since the 2011 nationwide EAS test and to improve its ability to monitor the performance of EAS Participants during nationwide EAS tests. At the direction of the Commission, the Public Safety and Homeland Security Bureau launched the EAS Test Reporting System (ETRS), an electronic filing system and related database, on June 27, 2016. Using ETRS for the first time, EAS Participants nationwide registered accounts and submitted identifying information regarding their participation in the EAS. In the hours following the nationwide test, EAS Participants submitted “day of test” results that indicated whether they successfully received and retransmitted the test alert. EAS Participants submitted detailed analyses in the weeks following the test that specified how they received the alert and identified any complications they experienced during the test.

The FCC reports that the Nationwide EAS Test was successful. Initial test data indicates that the vast majority of EAS participants successfully received and retransmitted the National Periodic Test (NPT) code that was used for the test. The improvements made to the EAS using the lessons learned from the 2011 nationwide EAS test and the implementation of the ETRS appear to have significantly improved test performance over what was observed during the 2011 test.

From the data submitted by EAS participants to the ETRS, several steps have been identified where the Commission could strengthen the EAS. These improvements address problems with poor audio quality, inability to deliver the Spanish alert because of receive timing between the over-the-air test and the IPAWS CAP alert, better access to alerts for people with disabilities, shortcomings in some state EAS plans, improperly configured station equipment, and potential improvements in cybersecurity of the EAS.

Read the FCC’s public notice:
https://apps.fcc.gov/edocs_public/attachmatch/DA-16-1452A1.docx
https://apps.fcc.gov/edocs_public/attachmatch/DA-16-1452A1.pdf

Be Prepared for the 2016 National EAS Test

EAS logoWith the pending national EAS test, and the FCC’s unveiling of the EAS Test Reporting System, the SBE has prepared this summary of dates and actions of which all stations should be aware.

Aug. 26, 2016
Stations must complete Form One in the ETRS

Sep 28, 2016, 2:20 p.m. ET
EAS test
If circumstances prevent a test on Sep 28, the secondary test date is Oct 5, 2016.

Sep 28, 2016
By 11:59 p.m. ET, stations must complete the day-of-test report on Form Two in the ETRS

Nov 14, 2016
Deadline to submit post-test data on Form Three in the ETRS

FCC Adds Three EAS Event Weather Codes

The FCC has released a report and order to add three new weather event codes for the Emergency Alert System. The codes are Extreme Wind Warning (EWW), Storm Surge Watch (SSA) and Storm Surge Warning (SSW).

Read the complete report and order at the FCC website.

From the R&O, the FCC will “require EAS equipment manufacturers to integrate these codes into equipment yet to be manufactured or sold, and make necessary software upgrades available to EAS participants no later than six months from the effective date of the rule amendments adopted in this order.”

While the new codes will not need to be added to EAS devices until 2017, the SBE has gathered information on adding the codes.

Gorman-Redlich Users
Gorman-Redlich will deliver new units with the codes as per the deadline. For existing units, contact the compoany. A new EPROM is likely required.

Monroe Electronics/Digital Alert System Users
DASDEC and R189 One-Net software version 3.0 already support these three event codes. If you have v3.0, no further action is needed, aside from selecting the codes from the drop-down menu if you want to use them.

Sage Alerting System Users
Sage plans to include the codes in the upcoming 89.30 release. To add the events now, use the “New Events” tab in the ENDECSetD settings program to define the new event code, then include the codes a filter as needed.

Trilithic Users
EASyCap B4020 software will be updated for the event codes. Users subscribed to the Trilithic Newsgroup will be notified when the update is ready. Starting Jan. 1, 2017, a radio-specific EAS product will be available. There are no plans to update the EASyCast platform. That product platform has reached the end of its service, so unless a large number of users request an update, one will not be released.

FCC Technological Advisory Council Opens Noise Floor Technical Inquiry

The SBE’s often-stated concerns about increases in ambient noise, especially in the AM broadcast band, have received a response from the FCC. On June 15, 2016, the Commission issued public notice DA 16-676 announcing that its Technological Advisory Council (TAC), an FCC advisory group, will investigate changes and trends to the radio spectrum noise floor to determine if there is an increasing noise problem. If it finds that there is such an increasing problem, the TAC will investigate its scope and the quantitative evidence available. Initially, the FCC on behalf of the TAC is asking how a noise study should be performed.

Comments from the public are due by Aug. 11, 2016. The SBE will file comments prepared with the assistance of its Government Relations Committee and its Executive Committee.

The comments from the public are intended to help the TAC determine the scope of the study. The TAC will seek to determine changes to the spectrum noise floor over the past 20 years. It is not frequency-limited, though most of the complaints in SBE’s experience typically concern ambient, man-made noise in the medium-frequency, high-frequency and VHF bands. Noise in this context denotes unwanted radio frequency (RF) energy from man-made sources. The FCC Public Notice indicates that the expectation of the TAC is a finding that the noise floor in the radio spectrum is rising. This assumption is based on the fact that the number of unlicensed, intentional and unintentional RF radiators and industrial, scientific and medical devices in use that emit radio energy increase. However, FCC cites a dearth of what it terms “concrete evidence” of increased noise floors and a lack of quantitative data to support the presumption. The TAC asks for help in strategizing how the available data can be added to, in order to advise FCC.

In the SBE’s view, this study is long overdue. SBE General Counsel Chris Imlay says, “The FCC does not have a working knowledge of ambient RF levels in different environments and has not had such for years. Without this, it is impossible to know whether the Part 15 radiated and conducted emissions limits for intentional, unintentional and incidental radiators are adequate. Because FCC has neither the resources nor the inclination to address individual cases of interference attributable to, for example, RF devices, power lines, switching power supplies, RF lighting systems and the vast array of other noise contributors in the field, it is critical that ambient RF be regulated prior to the point of retail sale. The results of this study will clearly help evaluate the adequacy of the current Part 15 and Part 18 regulations.”

The TAC is asking a very wide-ranging series of specific and general questions and many sub-questions about how an ambient noise study should be conducted and how noise should be evaluated, including the following:

1. Is there a noise problem?
• If so, what are the expected major sources of noise that are of concern?
• What services are being most impacted by a rising spectrum noise floor?

2. Where does the problem exist?
• What frequency bands are of the most interest?
• In what environments?

3. Is there quantitative evidence of the overall increase in the noise floor across various segments of the radio frequency spectrum?
• At what levels does the noise floor cause harmful interference to particular radio services?
• What RF environment data from the past 20 years is available, showing the contribution of the major sources of noise?

4. How should a noise study be performed?
• Would receiver noise measurements commonly logged by certain users (e.g. radio astronomers, cellular, and broadcast auxiliary licensees) be available and useful for noise floor studies?
• How much data must be collected to reach a conclusion?

The broadcast engineering community is both uniquely affected by increases in ambient noise, and uniquely qualified to participate in this study. The geographic distribution of SBE members in all RF environments makes SBE an asset to the TAC in the conduct of this study. All broadcast licensees, especially AM broadcast licensees, have a stake in this study. SBE members with input on this subject are urged to contact the SBE Government Relations Committeewith your thoughts on the issues listed in the public notice.

FCC Launches EAS Test Reporting System

The FCC EAS Test Reporting System (ETRS) is up and running. The system is for EAS participants to file identifying information, day of test data, and post-test data related to a nationwide test. The ETRS provides several new features that ease the data-entry burden on EAS participants, encourage timely filings, and minimize input errors. The ETRS also offers new data fields that are responsive to stakeholder comments.

Access the ETRS

The FCC will use this system for the September National EAS Test and future EAS regional and national tests. There are multiple steps involved in the reporting process. The first step is to complete Form One, which must be done Aug. 26, 2016. To complete the form, participants must register on the ETRS site using the station’s FRN number and a password. Once registered, the FCC will send ETRS account credentials and a link to the ETRS login page.

Adrienne Abbott, SBE member and Nevada EAS chair, compiled some details about the system. Every station will need to complete a Form One. Station groups have the option of designating a coordinator to handle the filings. The coordinator will have the ability to batch file the forms. The form requires call letters as they appear on the license, the facility number for each station and the name of the station’s legal owner. As information is entered, some information will automatically populate the form from the FCC’s CDBS. It is advised to verify the CDBS information is correct.

The transmitter coordinates will not self-populate and must be entered directly. Use decimal form and NAD 83. Licenses are issued with NAD 27, so those numbers cannot be used. The FCC provides a conversion tool, and some consulting engineers offer the station info. If a tower is registered, the coordinates on the registration are in NAD 83. A Google map should appear if the coordinates are close. Check the map for your exact tower location. It should be within one second of the location on your license. If not, correct the location on the license.

The form will ask for the station’s monitoring assignments, but there is no need to include the NWS NOAA Weather Radio frequency. Enter the broadcast stations. The form will also ask for the brand of EAS equipment being used and the firmware/software version. Check the manufacturer’s website to make sure you have the latest update before you enter that information.

After the test, complete Form Two with the initial results of how the test was received and rebroadcast. The FCC wants that information as soon as possible after the test. Form Three allows more time to add any details or other information about the test.

In the FCC announcement about the ETRS, there is mention of a new EAS Handbook. Read the complete FCC public notice.

FCC Schedules Online Public File Webinar for June 13, 2016

Washinton, DC – In May 2016, the FCC announced the the first group of entities being added to the Commission’s expanded online public inspection file database must commence using the database on June 24, 2016. The database was initially established in 2012 for use by television broadcasters.

On June 24, 2016, cable systems with 1,000 or more subscribers, DBS providers, SDARS licensees, and commercial radio stations in the top 50 Nielsen Audio radio markets with five or more full-time employees must place their new public inspection file documents in the Commission-hosted online public file database. In addition, these entities must place their existing public file documents into the online public file within six months after the effective date (Dec. 24, 2016). Entities will not be required to place in the online public file existing political file material.

On June 13, 2016, the FCC will conduct a public demonstration of the expanded Online Public Inspection File (OPIF), which will replace the current Broadcast Public Inspection File (BPIF) process. The FCC will exhibit the interface that will be used by broadcast television and radio stations, cable systems, satellite television, and radio systems to file documents in the online public file database. The demonstration will inform users of the design, layout, and content of the OPIF site, discuss how to upload information and files, and present the new Application Program Interface (API) functionalities. The demonstration will also be available online.

The demonstration will take place on June 13 at 1 p.m. EDT in the Commission Meeting Room at FCC Headquarters, 445 12th Street, S.W., Washington, D.C. 20554. It will also be streamed online. The link for the stream will be available at

https://www.fcc.gov/news-events/events/2016/06/demonstration-expanded-online-public-inspection-file-interface

The FCC’s helpdesk is available to answer questions regarding the OPIF database: 877-480-3201, 717-338-2824 (TTY) or https://esupport.fcc.gov/request.htm.

Additional info:
FCC Public Notice – June 2, 2016
Online Public Inspection File Demonstration Announced – June 13, 2016
https://apps.fcc.gov/edocs_public/attachmatch/DA-16-607A1.pdf

FCC Public Notice – May 12, 2016
Effective Date Announced for Expanded Online Public Inspection File Database
https://www.fcc.gov/document/effective-date-announced-expanded-online-public-file

SBE Files FCC Comments on AM Improvement

The Society of Broadcast Engineers filed comments in response to the Federal Communications Commission’s further notice of proposed rulemaking and the combined notice of inquiry in the AM Improvement Docket, 13-249. Its comments focused on a single issue first raised in the SBE’s comments filed in the proceeding in 2014, but not addressed by the FCC in its October 21, 2015, first report and order: that of ambient noise in the AM broadcast band specifically, and in the Medium Frequency bands generally. The SBE’s comments note that the Commission has made, and is currently examining additional short-term improvements in AM broadcasting in this proceeding. Although those short-term initiatives may be necessary to help the serious economic conditions for AM broadcasters, they are not going to lead to any meaningful, long-term improvement in MF AM broadcasting. To do that, the SBE asserts, the Commission is going to have to be willing to implement some difficult regulatory reforms that it has not addressed to date. It must develop and commit to a regulatory plan that, over time, will reduce the levels of man-made noise in the MF bands, and more broadly in the bands below 30MHz.

The FCC noted earlier in the docket that “AM radio is particularly susceptible to interference from electronic devices of all types, including such ubiquitous items as TV sets, vehicle engines, fluorescent lighting, computers, and power lines. The noise on the AM band that is caused by those sources is only expected to increase as electronic devices continue to proliferate.” The SBE suggested that this increase in noise is not inevitable. However, it is a serious and worsening problem. Citing the aggregate effects of Part 15 and Part 18 unlicensed devices, the SBE notes that the FCC does not have any practical ability to address the interference potential of unlicensed devices past the point of sale. Reductions in field staff available to conduct spectrum enforcement have made enforcement in interference cases involving unlicensed devices unavailable in the future. The only source of regulatory reform that has a meaningful chance to positively affect the noise floor over time are the regulations that create obligations on manufacturers and importers and dealers, prior to the point that the consumer deploys it.

Citing a study by the LBA Group, AM reception is dependent on the desired signal being typically some 26dB above the ambient noise level. The AM band is subject to AM coverage distortion, increasing noise threats, and interference from the proliferation of wireless systems, electronic devices and low-frequency radiators that distort AM signals more now than as recently as 10 years ago. The electric power grid has expanded, bringing noise contributions from corona, arcing, and other modes. AM stations have increased power to raise their signal-to-noise ratio in an attempt to preserve their coverage areas, often interfering with other stations. But there is a limit to power increases, both economically and technically, and those limits are now reached in many cases.

The SBE argues that AM listeners have media options, and that RF noise will make them exercise those options. When an RF lighting device or a Part 15 intentional radiator causes interference to their receivers, AM listeners receive interference. They will not suffer it; They will simply utilize different media. The SBE urges the Commission to commence an interference management plan for the AM band, based on rules that limit RF noise before it becomes an issue, not after the fact, and those rules have to be enforced. The FCC should also study current ambient noise in the MF band, with an eye toward updating older studies on the subject. This will permit a reasoned analysis of the Commission’s Part 15 and Part 18 rules and thus contribute to a controlled RF environment over time. The SBE suggested that AM broadcasting will never get better in the worsening RF noise environment in the bands below 30MHz without some regulatory relief.

Read the SBE’s filing.