In the Matter of
                    Review of the Emergency Alert System             

EB Docket No. 04-296

To: The Commission

COMMENTS
The New Jersey Broadcasters Association (the “NJBA”), its members being substantially all of the radio and television broadcast stations licensed to New Jersey,
hereby submits its comments in response to the January 10, 2010 Second Further Notice of Proposed Rulemaking, in which it is proposed to amend Part 11 of the Commission’s rules governing the Emergency Alert System (the “EAS”) to provide for national testing of the EAS and collection of data from such tests.

12. For little cost, manufacturers can include an FM radio receiver in mobile phones that would give consumers a convenient new way to access FM radio service, and more importantly, improve public safety by ensuring that broadcasters’ Emergency Alert System (EAS) messages and emergency information reach the widest possible audience via free-over-the-air transmission and FM based text alerting protocols. Second, it is a cost-effective way for ensuring that the public has ready access to lifesaving information. It would cost $1 or less per device to incorporate FM radio functionality in a mobile handset. For the benefit of the American public, FM radio reception in mobile handsets should be a critical component of any next-generation wireless emergency alerting solution. It must be emphasized, of course, that for these goals to be realized, any appropriation or funding grant made to the states for EAS systems and upgrades must be restricted in their use for the specific purposes for which they are intended and must not be diverted to other uses or to fund ancillary projects.