Today, I submitted a comment to the Federal Communications Commission regarding the proposed rule titled "Wireless Emergency Alerts; The Emergency Alert System; Modernization of the Nation’s Alerting Systems." I argue that the use of standardized symbology to denote hazard types can be useful, but there needs to be more targeted research on the use of the National Alliance for Public Safety GIS (NAPSG) symbol set before deployment. Additionally, I urge the Commission to remove the outdated exemptions which allow for more than one-tenth of a mile overshoot in geotargeting accuracy for sending the wireless emergency alerts.
Executive Summary
The Federal Communications Commission’s proposed rule titled “Wireless Emergency Alerts; The Emergency Alert System; Modernization of the Nation’s Alerting Systems” proposes to modernize how wireless emergency alerts (WEAs) are disseminated to the public and to improve the content of the messaging. My name is Gavin Fry; I am a research fellow on the Science and Innovation team at the Foundation for American Innovation, a think tank focused on fostering innovation, strengthening governance, and advancing national security. I appreciate the opportunity to respond to this proposed rule, which will have crucial implications for emergency communications in the U.S, especially through the lens of natural hazard risk communication. This comment will address the ideas of incorporating standardized symbology within WEAs and eliminating certain exemptions for the one-tenth mile overshoot of geotargeting. The implications of these comments are summarized below:
- The use of standardized symbology within WEAs can improve comprehension of the hazard type, but there needs to be more targeted research and consultations with social scientists before any deployment of the proposed NAPSG symbology in WEA messaging.
- Eliminating the 0.1-mile overshoot exemption for entities that use geocodes (FIPS codes) for geotargeting should be implemented if the technical capability exists. Eliminating these exemptions can help reduce over warning, which contributes to warning fatigue, opting out of the WEA system entirely, and the potential erosion of trust in WEAs more generally.
Promoting the Use of Symbols for Alerts
The FCC seeks comment on where the use of standardized symbology, identifying the type of hazard, could be useful in improving comprehension for people with disabilities and people with limited English proficiency, hasten public reactions to alerts, and reduce milling. The existing natural hazard risk communication literature is robust and crucial to consult on this front. Research shows that a number of variables influence whether someone will decide to take protective action in the case of an emergency alert. Factors such as the inclusion of protective action guidance, prior experience with a hazard, and general knowledge of a hazard influences this decision making process. So, promoting protective action through the use of WEAs specifically is a complex topic. The use of symbols in WEAs may serve as an effective tool to help aid the comprehension of the emergency alert, and there are some specific examples where they could be particularly beneficial.
Research in the southeast United States suggests that the Spanish translation of WEAs can be beneficial in improving message comprehension in Spanish-speaking communities, but there are considerable difficulties in translating the precise verbiage used in the standard WEA text. Additionally, the research showed that niche meteorological terms can be difficult to directly translate into Spanish, creating a sense of confusion during the emergency. The use of symbols to identify the hazard type, would be practically useful in aiding these groups during times of crisis communication.
In addition to language barriers, the use of symbols will be valuable for communicating the hazard type to those who may not have experienced that particular emergency before. For example, incorporating the symbol for a blizzard warning may be especially helpful for members of the public that recently moved to a location with more severe winter weather. Moreover, if a person from the inland U.S. visits the coast and receives a hurricane or tropical storm warning, then having a symbol to refer to may aid comprehension.
There is also evidence which shows that symbols may be one of the most memorable aspects of a WEA message. Research in early 2025 highlights some deep complexities in the use of icons and text within WEAs. One of the research findings showed that nearly half the participants in the study who were shown a WEA recall the inclusion of a warning logo (the current use of a yellow hazard symbol with an exclamation mark). Yet, only one person out of 20 in the study allocated visual attention to the alert logo. About half the participants noted that this was an important feature in the WEA when they were interviewed. Although limited visual attention was given to the warning logo, the inclusion of it in the WEA was deemed an important feature by over half of the participants. This suggests that there is comparatively limited cognitive effort given to interpreting the symbol itself, yet it proves to be a memorable part of the warning message. If a symbol were more effectively used to not only represent the presence of a threat, but the type of threat, then this could be an effective way to improve WEA messaging.
The FCC also requested comments on what standardized symbol set the WEAs should incorporate. The FCC mentions interest in the National Alliance for Public Safety GIS (NAPSG) Foundation symbol library. It is crucial to consider that the NAPSG symbols were created for mappers and geographers, not specifically for emergency communication. It is necessary to develop a more concrete understanding of how the NAPSG symbols are interpreted by the general public before there is any deployment within the WEA system, especially since the existing literature on this topic is thin. Additionally, it would be prudent to consult with expert social scientists in the field of risk communication and meteorology to help identify a specific symbol set that would be best suited for this need. These experts have the knowledge to advise on how the public interprets such symbols. Therefore, it is crucial to consult with these experts to identify the proper symbol set to be used in WEAs.
Although specific, peer-reviewed research on the efficacy of the NAPSG symbols is sparse, an exploratory study suggests that some of these symbols lack the concreteness to be effective indicators of hazards. The study showed that some NAPSG symbols that were very explicit in their depiction of the hazard—a fire, tornado, or flood to name a few—were easily comprehended by the surveyed respondents. Other symbols that were less explicit such as a special marine warning (depicting an anchor) had low comprehension. This pioneering research suggests that the NAPSG symbology should be heavily scrutinized by risk communication scientists before any deployment within WEA messaging. Symbols can be effective alongside the warning text, but more targeted research needs to be conducted on the NAPSG symbols.
Additionally, this preliminary research shows that symbols which directly depict the hazard are more easily interpreted than those that are merely associated with the hazard. For example, a symbol depicting a tornado directly represents the hazard; this is known as a pictorial symbol. These were shown to be more easily comprehended than those that were indirectly representative of the hazard—known as an associative symbol. As mentioned above, the anchor symbol used to represent a special marine warning is an associative icon. Olivas showed that there was low comprehension of this symbol and that pictorial symbols are more easily interpreted than associative symbols. Using the American National Standards Institute’s standard for designing effective safety symbols (achieving an 85 percent comprehension rate in a pool of 50 people), Olivas showed that only three of the NAPSG symbols passed (fire, extreme heat, and severe thunderstorm).
It is also important to consider the specific nuances of meteorological hazards (such as tornado warnings versus tornado emergencies) and the levels of risk associated with each of those messages. If a standard symbol was used to identify both a tornado warning and a tornado emergency, how could a symbol help differentiate between these risks? Within the NAPSG database, there is a standard symbol set for natural hazards such as tornadoes, floods, and earthquakes. But how can individual risks within these categories be communicated or improved upon through the use of a standard symbol? It is prudent to understand what audiences these specific symbols were designed for and the potential limitations in implementing them across the natural hazard library. Although the text would communicate the message, research has shown symbols and icons to be memorable aspects of the message. So, some level of differentiation would be needed in this context for the symbols used.
Additionally, it is well known based on prior research that attention-grabbing colors and certain graphics are processed more efficiently than text. The effort to create a more effective WEA could possibly be achieved through the use of symbols and icons that contain the proper color scheme. Since these symbols and icons require limited cognitive effort to digest and have been shown to be a memorable component of the message, the use of standardized symbols, if paired with the proper coloring to promote a sense of urgency, could prove useful for WEAs and should replace the current use of a yellow warning sign. These symbols require limited cognitive effort and attention, yet they can be one of the most memorable aspects of the WEA. Changing these redundant symbols to convey a stronger sense of urgency while conveying additional information by using a hazard-specific symbol could potentially make WEAs more effective.
The FCC should strongly consider consulting with risk communication experts to determine what color scheme to use in these symbols. Some research suggests that the most appropriate color to use for a hazard largely depends on the type of hazard. For example, should we use red to denote a winter weather hazard? The research previously mentioned examines the appropriate use of color through the lens of weather forecasting graphics. There needs to be more targeted research on the use of color in hazard warning symbols to establish what the ideal standardized symbology set would look like. However, there are precedents to follow. The NWS warning polygons for tornado warnings are denoted as red, a color that is widely associated with heightened alert, risk, and urgency. More recently, the National Weather Service has adopted a magenta-colored polygon for tornado emergencies, the most life threatening tornado-related warning the NWS can issue. It is vital to maintain consistency with these color schemes, especially since the existing research shows that color is a crucial factor in determining urgency and threat level. Furthermore, it is necessary to consult with meteorological professionals to ascertain the best color scheme for other hazards. For example, what is the best color to denote a winter storm warning or a flood warning in a WEA? If the FCC decides to adopt a standard color scheme alongside the symbology, it is crucial for it to collaborate and seek guidance from the NWS and social scientists to determine which color scheme should be used.
Strengthening WEA Geotargeting by Eliminating Outdated Exemptions
Ensuring that WEAs are only sent to members of the public that are immediately at risk is crucial. The phenomena of “warning fatigue” in the field of meteorology and hazard communication science is crucial and shows that people who receive alerts that are not directly pertinent to them erode the trust and credibility of those warnings. The FCC should take action to ensure that geographic overshoot of WEAs is minimized in any circumstance. If the technical capability exists, it is necessary to remove the 0.1 mile overshoot exemption for entities that use geocodes to send the WEAs.
Paragraph 64 of the FNPRM asks whether “receiving such geographically irrelevant alerts cause subscribers to opt out of receiving WEA messages?” The existing research surrounding the above question is clear, and evidence shows that receiving geographically irrelevant alerts can cause the message recipient to “opt-out” of the WEA messages. For example, a 2025 study found that warning relevancy is a crucial factor that determines whether someone may grow complacent or become desensitized to WEAs, especially given the rather intrusive nature of the WEA itself. The FCC should prioritize efforts to increase the accuracy of geotargeting by removing the geocode exemptions. Taking this action can help reduce the number of geographically irrelevant warnings that are sent. In turn, this can help improve the credibility of the WEAs and can help mitigate the effects of warning fatigue.
Research also shows that there are other variables that may contribute to a user opting out of the WEA messages. In the 2025 study, receiving geographically irrelevant warning messages was a notable finding. In addition, it was observed that message frequency itself could cause desensitization and opting out of the WEA messaging as well. If any technical constraints exist that can cause over alerting within WEA messaging, the FCC should take action to resolve these issues. Warning relevancy, warning frequency, and the intrusive nature of the WEAs were all factors that contributed to opting out in the study.
Indeed, WEAs are designed to capture the attention of the user and provide as much lead time as possible for preparing for an emergency. However, if these messages are received too frequently for populations that are not actually impacted by the hazard, this erodes the trust of the WEA, the public can become desensitized to the message, and can lead the user to opt out of the WEA messaging altogether. Attempting to make the geographic overshoot as small as possible can serve as a foundational attempt to help mitigate these issues.
Thank you for the opportunity to submit comments to this proposed rule. Wireless emergency alerts are a crucial component of our communications infrastructure, and the opportunity to modernize them alongside the meteorological and risk communication community is vital.
