On Thursday, November 21, 2019, CTIA filed an ex parte with the Public Safety and Homeland Security Bureau (“PSHSB”) requesting – at a minimum – a 14-day extension for service providers to meet the November 30 WEA deadline for enhanced geo-targeting deployment, due to outstanding testing with FEMA’s Integrated Public Alert and Warning System (“IPAWS”) that is necessary to reliably implement the enhanced WEA requirements, among other reasons. CTIA also encourages the Commission to acknowledge the current status of IPAWS WEA implementation, and to take steps to ensure that all stakeholders take care to mitigate any potential risks to the WEA system.

FEMA has indicated that IPAWS testing was ready to begin the week of November 18th, and is intended to conclude by November 29th to meet the November 30th deadline. CTIA has previously mentioned that end-to-end testing required to deploy WEA enhancements typically requires six months. Accordingly, CTIA contends this two-week period leaves inadequate time for appropriate testing and thus encourages the Commission to accommodate an additional 14 days, at a minimum, for FEMA and participating CMS providers to complete testing.

In addition, CTIA points out that FEMA has indicated the upcoming implementation of IPAWS WEA system update will not include all WEA 3.0 features, including the verification that alert message polygons adhere to no more than 10/100 vertices. CTIA explains that until FEMA has addressed this issue, there is the potential that non-conforming WEA messages will be delivered to the CMS Providers’ networks from IPAWS, which in turn may prevent CMS Providers from transmitting these WEA messages. Therefore CTIA requests that the FCC encourage FEMA to educate alert originators and their vendors of this limitation and have a mechanism to inform alert originators when such messages do not adhere to the 10/100 vertices parameter.

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