FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
|In the Matters ofAmendment of Part 11 of the Commission’s
Rules Regarding the Emergency Alert
Wireless Emergency Alerts
PS Docket No. 15-94
PS Docket No. 15-91
COMMENTS OF THE AWARN ALLIANCE
The AWARN Alliance, composed of broadcasters, consumer electronics manufacturers, and other technology companies,1 suggests a holistic, multi-faceted approach to improving emergency alerting, which would include both broadcast and broadband networks. No single alerting pathway can solve all the requirements of an advanced public warning system. A complementary “division of labor” among wireless networks, Next Generation Television, and ATSC 3.0-enabled mobile and other consumer devices presents the greatest opportunity to achieve the Commission’s goals. The Alliance also supports the Notice’s suggestion of dialogue regarding a voluntary industry roadmap for further enhancing the capability of the nation’s alerting infrastructure.
LEVERAGING ADVANCED TELEVISION TECHNOLOGIES IN ALERTING
The Advanced Warning and Response Network (AWARN), based on “Next Generation Television” technology, will provide a powerful new tool for significantly improving the content, accessibly, pervasiveness, and reliability of America’s emergency alerting systems. AWARN is a next-generation, dual-use, public alert and warning system for a mobile, 21st Century America.
AWARN will utilize the nation’s existing terrestrial television broadcasting spectrum and infrastructure and leverages Advanced Emergency Alerting (AEA) capabilities that are designed into the coming IP-based Next Generation Television broadcasting standard (see below).
Uniquely, AWARN will be able to distribute rich media alerts simultaneously to an unlimited number of enabled fixed, mobile, and hand-held devices, indoors or outdoors across an entire television broadcast coverage area. These capabilities will far exceed warning and disaster recovery communications available to the American public today.
INTER-INDUSTRY ALLIANCE FOR THE RAPID DEPLOYMENT OF AWARN
The AWARN Alliance applauds the Commission for its ongoing work to improve America’s emergency alerting capabilities, including this Notice of Proposed Rulemaking (“Notice”). The Alliance welcomes the opportunity, described in the Notice, to “dialogue about creating a voluntary industry roadmap for further enhancing the capability of the nation’s alerting infrastructure to carry a Presidential Alert in a manner consistent with consumer expectations of IP-based communications technologies.”2
The AWARN Alliance is one of four signatories (along with America’s Public Television Stations (APTS), the Consumer Technology Association (CTA), and the National Association of Broadcasters (NAB)) to the “Joint Petition for Rulemaking Seeking to Authorize Permissive Use of the ‘Next Generation TV’ Broadcast Television Standard.”3 The joint petition describes the many consumer benefits of Next Generation Television, including the AEA function that is a core capability of the new standard on which AWARN is built.
ALERTING AND THE WORLD’S FIRST IP-BASED TV TRANSMISSION PLATFORM
In its inquiry into the potential of new technologies to approach alerting, the Notice notes that “broadcast television is exploring IP-based offerings.”4 In fact, the broadcast television, consumer electronics, and allied industries have moved far beyond exploration to achieving major milestones in the development of the world’s first IP-based broadcast transmission platform, also known as “ATSC 3.0” or Next Generation Television.5 The Advanced Television Systems Committee (ATSC), an international, non-profit organization, has worked intensively over a number of years to develop the voluntary suite of standards that comprise the new ATSC 3.0 next-generation standard that bears its name.6
In comments filed by the ATSC on May 26 in the Commission’s Public Notice seeking comment on the joint petition for rulemaking seeking to authorize permissive use of Next Generation Television,7 ATSC summarized some of the far-reaching capabilities of the new technology standard:
Unlike the current standard, ATSC 3.0 is based on Internet Protocol technology. It is, in fact, the world’s first IP-based broadcast transmission platform. As such, ATSC 3.0 merges the best capabilities of over-the-air and broadband viewing. ATSC 3.0 will allow broadcasters to present consumers with “more,” “better” and “new”– more streams, more choices, more channels, more flexibility, better picture, better sound and new personalization and interactive features that will enhance the experience of watching broadcast content. ATSC 3.0’s use of Internet Protocol, HTML5 and other web technologies enables the marriage of broadcasting and the Internet and its rich ecosystem of content, services and consumer devices…
[T]he standard will facilitate dramatic improvements in the robustness of signals, allowing improved indoor and mobile reception for the growing number of American households relying, in whole or in part, on over-the-air broadcasting to receive linear television programming. ATSC 3.0 also supports accessibility advances, such as multiple closed-captioning services and assistive audio for improved video description intelligibility. Equally significant, the standard has the potential to deliver enhanced emergency alerts and the capability to wake-up devices in “sleep” mode to deliver time- sensitive, often life-saving emergency information. Just as consumers will benefit from ATSC 3.0, so too will broadcasters.
The next generation broadcast platform made possible by ATSC 3.0 is exceptionally robust. It facilitates simple deployment of Single Frequency Network transmission systems that can greatly improve signal reception, particularly on mobile devices and television sets without outdoor antennas. As such, the platform can deliver TV signals deep inside buildings and on-the-go, allowing broadcasters to reach their audiences anytime, anywhere. New audience measurement tools also come with ATSC 3.0, as do advanced advertising features such as interactive and real time ad-targeting capabilities.
AWARN will leverage the native features of ATSC 3.0, as noted in the above-referenced ATSC comments, to achieve its major improvements in emergency communications.
NEW SOLUTIONS FOR MAINTAINING AND UPGRADING THE EAS
The Commission seeks to ensure that Emergency Alert System (EAS) alerts endure and remain reliable as technology advances. Further, the Commissions seeks comment on “whether EAS alerts offered through different technologies may have a greater potential to meet the emergency information needs of the public than do alerts offered via traditional media.”8 AWARN and Next Generation TV will not only ensure the durability of the EAS but also greatly improve its effectiveness in meeting the emergency needs of the public. One of the unique features of Next Generation TV is that it is both a traditional medium – broadcast television – and something completely new – a “high-power, high-tower, nationwide wireless IP network.”9 This combination of media types underlies the power of Next Generation TV to achieve the Commission’s goals for improved alerting.
GEO-TARGETING, PERSONALIZATION, AND THE “CYCLE OF INFORMATION SHARING”
The Notice asks specifically about the potential for new technologies to improve geo-targeting, offer personalization, and to “give rise to a cycle of information sharing consistent with a ‘many- to-one/one-to-many’ alerting dynamic.”10 Next Generation TV, through AWARN, has native capabilities that enable alerting to achieve all of these goals.
Geo-targeting and personalization are core capabilities of Next Generation TV that can be utilized by AWARN. Although all devices in a transmitter coverage area may physically receive the AWARN alert message, geocodes added to the message by alert originators combined with devices being aware of their location (either through a GPS-based (or similar) mechanism or via user setup) means that only alerts intended for a geographic area will be displayed on enabled devices that are in that area. Likewise, personalization allows users the option to display alerts that are intended for another geographic area, such as a child’s school, when the parent is away at work. Personalization also allows users to pre-determine the types of (non-Presidential) alerts or hazard levels that will trigger the display of an alert on their device.
Next Generation TV also is perfectly designed for a “many-to-one/one-to-many” alerting system. High-power signals transmitted from tall towers allow the Next Generation TV signal to blanket an entire coverage area. And the all-IP nature of Next Generation TV enables the instantaneous formation of “hybrid networks” to provide a seamless return path using an enabled receive device’s connectivity. For example, a smart TV may receive the robust Next Generation TV signal through a small indoor antenna while also connected to the Internet via Wi-Fi or Ethernet. A mobile device may receive the Next Generation TV signal indoors or outdoors while maintaining a cellular or Wi-Fi connection. This hybrid connectivity allows for instant interaction with the alert content via “clickable URLs” embedded in the message for social media or other communications pathways.
The technological innovation of Next Generation TV hybrid networks builds upon years of experience by broadcasters to “crowd source” information during the creation of their news and weather programming.11 Next Generation TV will enable broadcasters and consumers to take this “cycle of information sharing” to a whole new level, especially during emergencies. This crowd sourcing will continue to enhance the role of broadcasters as “first informers,” but data from hybrid networks can also be directed to emergency managers to help them create a “common operating picture” during a public emergency.
ABILITY TO “WAKE UP” DEVICES
Advanced alerting is designed into the core “physical layer” of the ATSC 3.0 standard and is carried in the highly robust system discovery or “bootstrap” signal of the television transmission. The bootstrap component of the ATSC 3.0 suite of standards was the first to receive final approval by the global ATSC. Transmitting AWARN alerts in the bootstrap means that all ATSC 3.0-enabled receive devices, whether smart TVs, tablets, or smartphones, will receive the alerts. It also offers the possibility that these devices can be designed to “wake up” when an alert is received. As noted in the April 13, 2016 Joint Petition for Rulemaking for the permissive use of the ATSC 3.0 standard for broadcast transmission:
This new standard will enable life-saving advancements in emergency alerting, which could include: Signaling that permits receivers to alert consumers of an emergency even when the receiver is powered off. This functionality can be used to cause the receiver to “wake up” to process emergency alert information – an invaluable advance, particularly in areas prone to tornadoes, earthquakes and other sudden disasters (in addition to man- made emergencies)…12
A leading broadcast technologist explained how the bootstrap technology works for alerting:
The bootstrap signal also will play a key role in emergency alerting. For example, a portable receiver in a tablet or cellphone only has to turn its receiver on long enough to pick up the bootstrap signal (2 milliseconds). The receiver does not need to decode the preamble or the rest of the frame or turn on additional demodulation circuitry until the bootstrap signals that an emergency alert is available, reducing power consumption and thus providing longer battery life. When an alert is received, it can switch on the demodulator and receive and display the emergency message and supplemental data.13
AWARN’S RICH MEDIA CAPABILITIES
The AWARN Alliance supports policies to offer expanded and enhanced alert messages. As noted in comments filed by the AWARN Coalition (a predecessor to the Alliance) in an earlier proceeding for improving Wireless Emergency Alerts (WEAs),14 simply including telephone numbers and URLs in WEA messages, as proposed in the Notice, can accelerate network overload as people try to make calls or click on web links. Similarly, including rich media elements (such as photos, videos, and evacuation maps) in a WEA alert can lead to wireless network congestion and failure.
A better approach is to leverage the rich-media capabilities of AWARN combined with the internal memory of mobile and other smart devices to receive and cache vital emergency information that cannot fit into a text message. Instead of users requesting critical information by calling a number or accessing a website, users can receive life-saving information that is ubiquitously transmitted and stored in the background on devices as the initial alert is sent. If wireless network connectivity is available (more likely if alerting content is off-loaded from the network by AWARN), users can click on links or phone numbers embedded in the AWARN message.
Rich-media emergency information is sent by alert originators using the Common Alerting Protocol (CAP) and the Integrated Public Alert and Warning System (IPAWS) of the Federal Emergency Management Agency (FEMA), transmitted via AWARN over the broadcast signal, and can be downloaded in the background to user devices. The content could include video, radar images and evacuation maps; text, photographic, or pictorial instructions; inundation maps; plume models for chemical or radiological releases; and shelter locations, treatment protocols, and other recovery information. Stations that produce their own news and weather programming would have the option of inserting their own clips as additional rich-media elements into the alert. People in harm’s way would have this deeper alert and response information sent via AWARN literally at their fingertips. They would only need to open a menu on their device and select the files most relevant to them.
OPPORTUNITY AND CHALLENGES FOR ALERT ORIGINATORS
The bandwidth provided by AWARN creates opportunities for alert originators to aggregate much more rich media content for the alerts than they can easily disseminate to the public today. As noted above, this content may include video (such as from surveillance cameras), radar images and evacuation maps; photographic, or pictorial instructions; inundation maps; plume models; and other content that people need to take action to protect themselves or others. For this reason, the AWARN Alliance suggests that the Commission also assess the readiness and capacity of emergency managers and alert originators to acquire, aggregate, and assemble into CAP format rich media content that can leverage the greatly increased transmission capacity of AWARN. It may be that efforts are necessary to encourage, train, and support emergency managers to take full advantage of the capacity that AWARN offers.
VOLUNTARY APPROACH IS LEADING TO INNOVATION
We applaud the Commission’s goal of dialogue for creation of “a voluntary industry roadmap for further enhancing the capability of the nation’s alerting infrastructure…”15 ATSC 3.0 and AWARN themselves are the products of the voluntary commitment of resources from many organizations. Innovation in next generation emergency alerting that adheres to current public safety regulations and requirements, but which can explore new approaches as well, is most likely to lead to the continuing improvement that AWARN represents.
The AWARN Alliance itself embodies this voluntary commitment by major segments of the broadcasting, consumer electronics, and allied industries. Together, Alliance members Capitol Broadcasting Company, Pearl TV, and Sinclair Broadcast Group reach over 85 percent of U.S. television households. Pearl TV members own and operate more than 200 network-affiliated TV stations.16 Sinclair Broadcast Group owns or operates 171 TV stations and, through its affiliate, ONE Media, also has been a major contributor to the development of Next Generation Television. The National Association of Broadcasters (NAB) represents the television broadcast networks and local stations nationwide. PBS serves 350 member stations.
Other members of the Alliance include GatesAir, a leading television transmitter manufacturer, Monroe Electronics and its Digital Alert Systems subsidiary, whose EAS encoder/decoder equipment is in the majority of U.S. broadcast television stations and whose emergency information accessibility solutions are also widely used in the industry, and Triveni Digital, whose systems enable television broadcasters to deploy enhanced programs and services to their viewers. Another member is Airwavz TV, which recently unveiled a new mobile phone accessory – which operates in ATSC 1.0 but which plans to migrate to ATSC 3.0 – that will make it easier to view digital television on-the-go. Alliance member and consumer electronics leader LG Electronics and Zenith, its U.S. R&D subsidiary, are key developers of the technologies in the majority of the “physical layer” transmission system at the heart of the ATSC
The ATSC, which has created the ATSC 3.0/Next Generation TV standard, is an international non-profit organization that currently has approximately 150 member organizations representing the broadcast, broadcast equipment, motion picture, consumer electronics, computer, cable, satellite, and semi-conductor industries. Within the ATSC Technology Group developing ATSC 3.0, more than 30 specialist groups, subcommittees and ad hoc groups are actively engaged, participating in nearly 600 meetings in 2015 alone. Over the past year, ATSC expert volunteers spent an estimated 24,770 person-hours developing the ATSC 3.0 standard.17
A major subset of these same ATSC members worked to include AEA capability as one of the 13 native “use cases” for the new standard.18 AWARN represents the first implementation of these AEA capabilities. Many of the ATSC members who have supported AEA and AWARN worked previously to create the original Mobile DTV and Mobile EAS standards, which provide a solid foundation for AEA. The basic workflows for receiving CAP message from FEMA IPAWS that were developed for Mobile EAS using ATSC 1.0 have been transferred directly into AWARN workflows. Last year, FEMA began testing the first-generation Mobile EAS technology that underlies AWARN at its IPAWS Lab in Indian Head, Maryland.19
It also is important to note that, while transmission only of Presidential Alerts is mandatory for broadcasters, television and radio broadcasters have for many decades carried state and local alerts voluntarily and at their discretion to balance the needs of their viewers. This arrangement has served local communities and the nation well and continues to be the backbone of our alerting system at all levels, as noted in the Notice. This voluntary cooperation among the various federal, state, local, and tribal alert originators, broadcasters, and other stakeholders will continue into the future as the IP-based AWARN creates greatly expanded, yet targeted, alerting capabilities.
TECHNOLOGICAL POTENTIAL FOR IMPROVEMENTS IN ACCESSIBILITY
AWARN provides the technical capability to transmit both multilingual and accessible alerts. Features such as text-to-speech and vibrate-upon-alert for mobile devices, along with all of the rich media content available to users, mean that AWARN alerts will reach many more Americans, including those with aural or visual impairments. Besides AEA, accessibility is another native capability of ATSC 3.0.20
ADVANTAGES OF ALERTING INDEPENDENTLY OF THE INTERNET
The Commission seeks comment on the ability of “Over-the-Top” (“OTT”) alerting to improve EAS alert personalization.21 As noted above, the all-IP nature of Next Generation TV enables hybrid broadcast-broadband networks. AWARN alerts can work interactively with OTT content and user interfaces. Fortunately, AWARN provides capability for personalized alerting regardless of whether an Internet connection is available. Personalization can be handled locally, on the device, through options presented to the user in an application on the device.
Given the strong interest in production of ATSC 3.0-enabled receive devices by major players in the consumer electronics industry (see infra bullet notes § Next Generation TV Launching 2017), it is plausible that ATSC 3.0 receive capability in consumer devices could become as ubiquitous as Wi-Fi radios in devices today. In this way, the power of Internet Protocol in Next Generation TV can be harnessed to bring many of the advantages of OTT alerting without the need to access the actual Internet.
NEXT GENERATION TV LAUNCHING 2017
ATSC 3.0, in development since 2013, is on track for widespread deployment and with it AWARN:
- In February 2016, leading South Korean broadcasters announced that they will begin transmitting ATSC 3.0 broadcasts in February 2017.22 Korea’s progress in ATSC 3.0 deployment is significant for the United States because both are “ATSC countries” and among U.S. broadcasters “…there is keen interest in South Korea and their fast-track launch of next-generation ”23
- In April at the NAB Show 2016, LG Electronics and its Zenith R&D subsidiary showcased a new wireless network antenna that can receive and process Next Generation TV broadcast signals and redistribute them via Wi-Fi. It was built around the world’s first ATSC 3.0 tuner demodulator 24
- Sinclair and LG conducted the first over-the-air broadcast of AWARN alerting using the ATSC 3.0 standard at the NAB Show 2016.25 The alert was transmitted from Las Vegas’ Black Mountain on Channel 45, under an experimental FCC license obtained by ONE Media, Sinclair’s joint venture, and received with a simple antenna and LG’s new ATSC 3.0 chip tuner/demodulator at the Las Vegas Convention Center.
- Last year, Samsung Electronics America agreed to work with the Pearl TV consortium and Sinclair Broadcast Group “to support the development and implementation of the ATSC 3.0 standard.”26 Samsung, the world’s largest smartphone manufacturer, also announced new Next Generation Television products at the NAB Show 27
- To date, of the 20 total standards that comprise the ATSC 3.0 suite, one is now a final standard, one is at the last steps of finalization (Proposed Standard), and eleven more have advanced to Candidate Standard level.28 Essentially, the major core elements of ATSC 3.0 are in the final stages of standardization, which will allow voluntary adoption by U.S. broadcasters in the very near future, subject to Commission permission for voluntary transmission.
- The explicit backing of the Joint Petition for Rule Making by the Consumer Technology Association, which represents consumer electronics manufacturers, underscores the industry’s strong interest in swift commercial adoption of Next Generation TV-enabled consumer products.
AWARN presents a rare opportunity to dramatically improve America’s public safety communications capability. AWARN can provide this public benefit by dual-use of the backbone of the nation’s existing television broadcasting transmission capacity and the new technology of ATSC 3.0. It delivers rich media content to an unlimited number of mobile and fixed devices simultaneously, and since AWARN is completely independent of the cellular networks, it can actually reduce stress on those networks in public emergencies. This means high reliability and mass, but targeted, instantaneous distribution. Both AWARN and ATSC 3.0 are technologies that are on track for U.S. deployment. Because they are IP-based, both are extensible, allowing for technological improvements with time. The AWARN Alliance urges the Commission to include AWARN as enabled by ATSC 3.0 in its plans for advanced emergency alerting but to allow implementation details to be worked out by the industries and other stakeholders involved.
By: /s/ John M. Lawson
Executive Director AWARN Alliance
1602 Belle View Blvd #570
Alexandria, Virginia 22307
June 8, 2016
1 The AWARN Alliance is composed of Airwavz.TV, Sinclair Broadcasting Group, Pearl TV, Capitol Broadcasting Company/WRAL, Digital Alert Systems/Monroe Electronics, Gates Air, LG Electronics/Zenith, ONE Media, National Association of Broadcasters, PBS, and Triveni Digital.
2 See Notice of Proposed Rulemaking: In the Matters of Amendment of Part 11 of the Commission’s Rules Regarding the Emergency Alert System PS Docket No. 15-94; Wireless Emergency Alerts PS Docket No. 15-91 at ¶ 75
3 See Media Bureau Seeks Comment on Joint Petition for Rulemaking of America’s Public Television Stations, The AWARN Alliance, The Consumer Technology Association, and The National Association of Broadcasters Seeking to Authorize Permissive Use of the “Next Generation TV” Broadcast Television Standard, Public Notice, GN Dock- et No. 16-142, DA 16-451 (rel. Apr. 26, 2016).
4 See Notice at ¶ 88
5 “President’s Memo: Broken Record and Breaking Records,” The Standard, ATSC.org, the Advanced Television System Committee, June 2016 http://atsc.org/newsletter/presidents-memo-broken-record-and-breaking-records/
6 Formed in 1983, the ATSC developed the current ATSC Digital Television Standard (now known as “ATSC 1.0”), which was adopted by the Commission in 1996 and has been serving American consumers with HDTV and multicasting services since 1998.
7 See Comments submitted by the Advanced Television Systems Committee, Inc. in response to Media Bureau Seeks Comment On Joint Petition for Rulemaking of America’s Public Television Stations, The AWARN Alliance, The Consumer Technology Association, And The National Association Of Broadcasters Seeking To Authorize Permissive Use Of The “Next Generation TV” Broadcast Television Standard GN Docket No. 16-142
8 See Notice at ¶ 91
9 See “Summit: 3.0 Could Be Boon to Public Safety,” TVNewsCheck, November 19, 2015, quote from Sam Matheny, Executive Vice President and Chief Technology Officer, National Association of Broadcasters, at the Smart Spectrum Summit http://www.tvnewscheck.com/article/90179/summit-30-could-be-boon-to-public-safety
10 See Notice at ¶ 91.
11 See comments by Peter Sockett, director of engineering, WRAL in Raleigh, NC in “AWARN Receives Strong Support at First-Ever Smart Spectrum Summit,” blog at AWARN.org, published November 2015. http://awarn.org/blog/awarn-receives-strong-support-at-first-ever-smart-spectrum-summit/
12 Joint Petition for Rulemaking, In the Matter of Authorization of Next Generation TV for Permissive Use as a Television Standard, by America’s Public Television Stations, AWARN Alliance, Consumer Technology Association, and National Association of Broadcasters (filed April 13, 2016)
13 Doug Lung, vice president of technology, NBC Stations, Western Region in his column “The ATSC 3.0 Physical Layer—Bootstrap Basics,” TVTechnology, December 23, 2015 http://www.tvtechnology.com/expertise/0003/the- atsc-30-physical-layerbootstrap-basics/277638
14 See Comments by the AWARN Coalition In the Matter of Improving Wireless Emergency Alerts and Community-Initiated Alerting, PS Docket No. 15–91; FCC 15–154
15 See Notice at ¶ 75
16 Pearl member companies are Cox Media Group, the E.W. Scripps Company, Graham Media Group, Hearst Television Inc., Media General Inc., Meredith Local Media Group, Raycom Media, and TEGNA, Inc.
17 See Supra note 8
18 The 13 use cases of ATSC 3.0 are: Flexible Use of Spectrum; Robustness; Mobile; Ultra HD; Hybrid Services; Multi-view/Multi-screen; 3D Content (Video); Enhanced & Immersive Audio; Accessibility; Advanced Emergency Alerting; Personalization/Interactivity; Advanced Monetization; and Common World Standard
19 “FEMA to Assess Future Over-the-Air Broadcast Alerting Technology,” FEMA News Release Number: HQ-15-073, October 20, 2015
20 See supra note 18.
21 See Notice at ¶ 95
22 Tom Butts, TV Technology: “Korea to Launch ATSC 3.0 Broadcasts in 2017,” TV Technology, February 24, 2016 http://www.tvtechnology.com/atsc3/0031/korea-to-launch-atsc-30-broadcasts-in-2017/278022
23 Sam Matheny, Executive Vice President and CTO, NAB, as quoted by Deborah McAdams, TV Technology: NAB 2016: LG, Korean Broadcasters Demo ATSC 3.0 Progress – April 17, 2016
24 “NAB 2016: A Lot of Firsts for ATSC 3.0,” Broadcasting and Cable, April 14, 2016
25 “NAB 2016: Sinclair, LG Test ATSC 3.0 AWARN,” TV Technology, April 18, 2016
26 “Samsung Moves Forward on ATSC 3.0 With Pearl TV, Sinclair,” Broadcasting and Cable, June 17, 2015
27 “Samsung and LG Focus On ATSC 3.0 UHD Transmission At NAB,” CDRInfo, June 7, 2016
28 See ATSC.org – http://www.atsc.org/standards/candidate-standards/ “A Candidate Standard is a document that has received significant review within a specialist group. Advancement of a document to Candidate Standard is an explicit call to those outside of the related specialist group for implementation and technical feedback. This is the phase at which the specialist group is responsible for formally acquiring that experience or at least defining the expectations of implementation.”