Station Compliance›Field Notes

Television has an emergency obligation radio does not, and it fails silently. The crawl looks right on the monitor wall, the audio sounds right in the control room, and the part that is broken is a stream nobody in the building is listening to.

What the rule requires

§ 79.2 splits the obligation by who is being left out.

For viewers who are deaf or hard of hearing — § 79.2(b)(1) requires that emergency information delivered in the audio be made accessible "through closed captioning or by using a method of visual presentation." Audio emergency content needs a visual equivalent.

For viewers who are blind or visually impaired — the requirement depends on where the information appears:

• In a regularly scheduled newscast (§ 79.2(b)(2)(i)), emergency information provided visually must be made accessible. In practice the anchor reading what is on screen satisfies this.
• Outside a newscast (§ 79.2(b)(2)(ii)) — the crawl during syndicated programming, the alert over a network feed — the information "must be accompanied with an aural tone" and, since May 26, 2015, must be made accessible "through the use of a secondary audio stream."

The three specifics that get missed

The secondary audio requirement is not simply "say it somewhere." § 79.2(b)(2)(ii) is precise, and each element is a separate way to fail:

1. Preceded by an aural tone. The tone is what tells a listener on the secondary stream that what follows is an emergency message rather than description or alternate-language audio.
2. Conveyed in full at least twice. Once is not compliant. A system that speaks a long crawl a single time as it scrolls past does not meet this.
3. Intelligible, with correct pronunciation. Where text-to-speech generates the audio, the rule expects the relevant information — place names in particular — to be pronounced correctly. A synthesiser that mangles the county name is not conveying the information.

What counts as emergency information

§ 79.2(a)(2) defines it as information about a current emergency intended to further the protection of life, health, safety and property — and the examples given are ordinary local ones: tornadoes, hurricanes, floods, earthquakes, and school closings.

School closings matter here. Stations that think of this rule as a severe-weather obligation run closing crawls all winter without the secondary audio path doing anything, because a closing does not feel like an emergency. Under the definition, it is covered.

Why it fails without anyone noticing

Every other on-air fault announces itself. Dead air, a black screen, a stuck crawl — somebody sees it within a minute.

The secondary audio stream has none of that feedback:

• Nobody in the building monitors it. The confidence feed is the main program audio.
• The people who would notice are not in a position to report it. A viewer relying on SAP for emergency information is, by definition, not watching a crawl they can compare against.
• It is the same encoder path as descriptive video, which is often configured once at commissioning and never revisited.
• The failure is partial. SAP carries audio, so a spot check finds something there — just not the emergency information, or not twice, or without the tone.

The result is a station that is confident it complies because the crawl is visibly working, which is the half of the obligation that was never in doubt.

Testing it, which takes fifteen minutes

1. Run a test crawl outside a newscast — the RWT is a reasonable vehicle, or use whatever test path your automation supports.
2. Listen to the actual secondary audio stream, not the program audio. On a consumer receiver that is the SAP or alternate audio track. Use a real receiver rather than a router output, because you want to hear what a viewer hears.
3. Check all three elements. Was there a tone first? Was the message spoken in full twice? Were the place names intelligible?
4. Check a school-closing crawl too, not only a weather alert. Different origination path, and often a different result.
5. Write down what you found. Like § 11.35(d), there is nothing to file. The record exists so the next engineer knows it was verified and when.

How this connects to the September deadline

The same devices are involved. The character generator that puts the crawl on screen, the captioning encoder, and the audio chain that builds the secondary stream are all equipment that inserts content into the transmission of your programming — which is the scope language in § 11.35(d), the security rule that takes effect September 29.

So the walk you are already doing for the security deadline passes every device that carries this obligation too. You are in front of the gear anyway. Checking that the SAP path actually speaks the crawl is a fifteen-minute addition to a job already scheduled, and it closes a gap that has no other way of surfacing.

The TV scope guide lists what § 11.35(d) covers in a television plant, and the rule reference covers the three security requirements in full.