SES, Yakon Canadit EB Pon fit December 12,2018 To: Mr. Claude Doucet secretary Genera CCanasian Radio-television and “elecommunicatons Commission otawe, Ontario Subject: 171 Application Requesting that the Commission Amend Telecom Regulatory Policy (RTC 2017-91 to Ai forthe Establishment ofa Harmonized Emergency Alerting Public ‘Awareness Test Scheduler the Natonal Publ Alerting System Introduction 1 Thisapplcation - pursuant to Par ofthe CRTC Rules of Proctice and Procedures the “Rules ‘sbrought by Federal/Provinia/Tertitral Senior Officials Responsible for Emergency ‘Management (F/P/TSOREM (‘te Applicant" withthe expressed suppor of Pelmorex Cor, the Canaan Wireless Telecommuniations Associaton and the Pelmorex Alerting Governance ‘Cound ("the Governance Coun). Combined, the Applicant and supporters represent al stakeholders involved in creating validating and distributing emergency alert messages to CCenatians. The Appleat requesting the Comision mend Telecom RegulatryPaliy CRTC 2017-9 toallow forthe harmonization ofthe test messoge Schedule and policies aross all emergency alerting dstibution channels ~incusing radio, television and witeess devices. 2. Specially, the Applicant requests thatthe Commision mandate that: +A minimum of one and amaximum of two wireless pubic alerting (WPA) sible pubic awareness test message: be sued per year, with one of those two visible tests taking lace during Emergency Preparedness (EP) Week in May, anda second taking pace in November. 3. tfapprove, ths amendment wold enable F//T SOREM to adapts current recommended "National Public Aleting System (VPA) test schedule for broadcast television and rato, which allows for scheduling of up to five public awareness tests per year and reduce this number toa ‘maximum of two test per year, aaning with witeles tests during May EP Week and Novernber. ‘With the soppert ofthe Gavernance Coun, this new policy would be implemented within the 'NAAD System, and result ina syrchroized pubic awareness est policy and schedule hat ‘Would conse of two atchannelpublc awareness tess per yar CTC Part 1 Application 1‘Background: Exiting Public Emergercy Alerting Test Schedules |4. The SOREM Pubic Alerting Working Group (PAWG) has previously established a broadcast public awareness test ale sehedule that includes fe vibe tests per year. The Commission Fequestedin oadcostng Regultor Policy CRTC 2014484 that the Governance Cound ‘coordinate NAAD System ts. This Regulater Pley apples specfaly to broadcasting ‘istrbution undertakings, rio broadcasters and over-the-air television broadcasters. The Governance Counc approwtd the Curent NAAD System test policy effective Ap 1, 2015, win incarprates SOREM PAW's recommended fie annual public awareness test. The INAAD System Test Messages Policy v2.1 stats that public awareness test messages carted by ‘io and television may be scheduled by a provincial or territorial Emergency Management (Orgaizatin ("EMO") “to our up toa masimum of times per year (Sx/ear, wth four test ‘messages occuring on the third Wednesy of ever third month ofeach calendar year ‘beginning with March plus one test message occuring in May each year during Emergency Preparedness week”, ‘5. The Commision established separate parameters fr wireless publc alr tests through Telecom Regulatory Policy CRTC 2017-91, ts which it determined, based ona consensus OSC repor, that “ely one tex alert per yearshould be sent over the mandatory (se reeption channel uring Emergency Preparedess Week and that alother test lr shouldbe sent over the test [invisbe] channel Accordingly, the fist visible wieless tests were conducted in Canada on May 7 and 9 2018, and were concurrently dstibuted by participating provinces and territories via radia television, and wiles devices. s perth current egultor pac, the next vse WPA test wil not ake place unt May 2018. 6, ‘The resus current NPAS public awareness est schedule or emergency alerts in which one test during May EP Weet) is visible oer al pubic alerting chants (TV, asi ae wireless), ‘and four tests are only visible over TV and radio channels Current F/P/7 SOREM and the “Governance Counc are able to amend the NPAS and NAAD Sytem’ roadeasting est schedule ‘and polcy as needed, but a Commission deckon f required for amendments tothe WPA test Schedule set out ia CRTC 201791. Rationale for Harmonization 71 the Applicant and supporters belive the curent discrepancy between the test schedule for icles devices and aco and television ely to cause public confusion since test messages sl be delivered quarter hraugh radio and television and only annualy through wrees. The broadeast-oniy test are ver likely to result in Canadians questioning whether the wicless system is out-of-ync with he other alert delvry mechanisms or not working at al These diferent est Scenarios akoreduce the opportunity to increase public awareness of allthe alert *patlonl Ale Agreeaton and Oiserinaton System Test Messages oly 2.1 Api, 2015. "Telecom Deon 201791 (paagragh 82) and CRC 2018108 oarayaph 3 (REC Pact Aplestion 2istibution channels and the important fact thatthe NPAS, own tothe public as Alrt Ready, isone system with many detvery mechanisms. 8, ‘The May7 and, 2018 wires ive-to- test emergency ales ested in sigiicant publ awareness ad interest in Alert Ready and the addin ofthe new WPA channel. Provinces an ‘ertries, in consultation with F/2/TSOREM, cancelled the June 20, September 19, December 19 2018 and March 202019 veto air quarery radio and television tess to reduce public confusion around broadcasters and wireless pubic alerting veto tests 9, ‘The Applicant and supporters believe that the im af visible alert testing is to test the system Slerting serves. Conducting one test per year misses the oppertunty to increase pubic awareness by reinforcing the publ’ memory abou the nev alerting technology. 10, We believe that the current inl tests, used fr techalesl purposes, are portant to the alerting partners suchas the Commision, WSPs andthe alert agregatr, ang therefore should remain n place a per the Camission’s previous dedsion, Parameters elated tothe scheding of ove tests would be incorporated into an updsted NAAD Sytem Test Message Policy, ending the results ofthis application process. \Marmoniae Broadcast and Telacommunlcation Vibe Test Emergency Alert Schedules 11, The Applicants therefore requesting the Commision amend Telecom Regulatory Paley CRTC 201791 oallow the two emergency alert est message pales and schedules tobe harmonized in a manner tat esultsin the sole delivery of NPASal-chann!vble test rmestages As ees, puicawareness test messages, a received by Canaan, wil always fully replat the alerts issued by EMO, which erica to buling and maintaining public confidence inthe national ad provincia alerting inatives. 12, Consultation among public alerting stakeholders has resulted inthe recommendation that ‘otmonized visible publc awareness testing occur twice per year once during Emergency Preparedness Week as per te curret WPA test schedule and once sx month ster onthe fist ‘Wednesday in November. he propose policy change is approves, the Governance Counc ‘will approprately amend the NAAD System Test Messages policy, which so inciudes timelines {or identitying test dates and making thers avaible to distribtors a the publi. The twice per yar occurrence will provide sufient public awareness opportunities during the itl ‘phase of WPA deployment, a well as opportunities to test system, equipment, ad issuing procedures, without causing undue public disruption. An amended policy could also encourage ill povinial and terial €MOs to participate in both annua tests whenever possible to ‘maximize the postive impacts of system testing. (CRTC Par Application a