[BC] Re: RE: That Guy at the PAB who inspected Dana Puopolo'sStation

[Mike McCarthy]

RE EAS.

The simple rule to know is EAS equipment can be where ever it is desired 
PROVIDED the insertion can be made in any normal mode of operation, 
monitoring stations content can be heard AND properly decoded, and the 
encoding path doesn't corrupt the EAS data stream for downstream 
decoding.  I specifically make no comment about methods of outbound 
conveyance as there are many means to convey content of sufficient quality 
which doesn't corrupt the EAS data stream.

In our case, our primary ENDEC's are located at the main business location 
some distance from the monitoring area and everything is backfed by a 
T-1.  In our main studio located in the CoL, we have a 2nd EAS box which we 
connect by ISDN when needed.  It passes the Encoded audio fine.

This has passed muster by both the AIP and counsel.

The key is remembering the EAS box can be anywhere as long as the above 
provisions are met.  That said, if the station could prove it had the 
ability to run a RWT while Matt was present, that would have gone a long 
way towards establishing the EAS equipment was installed, operating and 
available.  Though it would not have resolved any questions about reception 
adn decoding of the monitored stations.

In reading both Matt's and Dana's comments.... I think the bulk of the 
problems which Matt would not pass the station were legit.  Missing many 
tests on both sides of the RX and TX aisle and such is a valid reason to 
not initially pass the station. The station should have also been a more 
forthright in explaining how it's EAS system is configured.  But since Matt 
didn't ask, that opportunity was not given.

Now I will make a comment about using highly compressed audio paths for EAS 
monitoring.  We have specifically avoided using highly compressed low bit 
rate audio paths for backfeeding our EAS monitored stations. High data 
compression coding WILL corrupt the EAS AFSK integrity resulting is missed 
decoding. We instead opted for voice grade cards which are linear.  For the 
most part, they have worked without error IF the levels are not clipped and 
more than 30dB S/N is present.

I suspect the backfed monitored stations were sent by a highly compressed 
path and as a result, the tests sent were not decoded because the audio was 
so deeply "distorted" from the compression. There are some things which 
compression is actually harmful. AFSK encoded "data" is one of them.

In this instance after reading the comments, I think Matt was in line with 
his responsibilities as the AIPI.  However, more probing of the EAS 
configuration might have removed some of the anxiety. But I too would have 
not passed the station based on inconsistent and missing tests alone.

IMHO....MM

At 03:03 AM 3/4/2009 -0500, Matthew Lightner wrote

>Mr. Puopolo,
>
>         The fact is the station in question was not in compliance with Part
>11 rules because many of weekly tests were missing. Maybe it was due to a
>technical problem, maybe the operator didn't log them, but it was not in
>compliance. The logs showed a test from the LP1 one week, the next week
>maybe a test from the LP2, the next week not any tests, etc. So the received
>tests were very sporadic. The EAS log had nothing explaining why the tests
>were missed. Also many of the events were expired when received due to the
>clock being off on the EAS unit. If the FCC walked into this station they
>very well would have issued a NOV.
>
>         As far as the local Pennsylvania studio streaming up to
>Massachusetts then back down to the transmitter in PA, I guess I was
>misinformed. I looked for a local EAS insertion device at the studio and at
>the transmitter site and did not see one. I did not go any further with this
>since the above issues needed corrected before I could pass the station. It
>was not made clear to me at the time that the local studio that is very
>close the transmitter site, streamed from PA to MA then back to PA.
>
>         So was my suggestion that your client install a local EAS unit
>wrong? I'm looking for the opinion of other engineers on the list. As an
>ABIP inspector, I am required to inspect the EAS system. How for sure did I
>know the system was setup to automatically interrupt the program chain
>without driving over 6 hours to the location of your ENDEC in MA to see if
>it was setup correctly. If a FCC field inspector came to inspect your
>station in PA, would they send someone to MA to inspect the EAS? Primarily
>the suggestion was made to install a local EAS due to the history of the EAS
>logs. Something was wrong that caused tests to be missed from both the LP1
>and LP2 on many occasions. If the logs were fine, I would have consulted
>others to see if it was ethical for me to certify a station for ABIP
>compliance without physically inspecting the EAS equipment.
>
>         I've inspected a few stations were the EAS unit is at the
>transmitter site and operated remotely, but I have to admit you had a first
>with it being over 6 hours away from the transmitter/local studio. I like
>people that think outside of the box. I just worry about the reliability of
>the internet if something happens that we need EAS for a national event.
>That is a complete other topic.
>
>Thank You,
>
>Matt Lightner - President
>Lightner Electronics Inc.
>www.LightnerElectronics.com
>Engineering Consultant/PA EAS Technical Chairman
>Pennsylvania Association of Broadcasters
>www.PAB.org
>(814)-239-8323 Phone
>(814)-239-8402 Fax
>
>-----Original Message-----
>
>  From: Dana Puopolo
>Puopolo'sStation
>
> >I will imbed comments.
>
>From: "Matthew Lightner" <matt at LightnerElectronics.com> n
>
>Everyone on the list:
>
>I am the inspector who inspected Dana Puopolo Client's Station. Before
>people starts throwing pitchforks at me I think you need to know the true
>story. I need to be careful here since the PAB keeps information from ABIP
>inspections confidential. So I'm not going into complete detail, or naming
>the station.
>
>Thank you.
>
>The fact is when I inspected the station Pupolo is talking about I looked at
>the EAS logs and found many discrepancies. Many of the received weekly tests
>were missing. I also recall the time was way off on the ENDEC unit. Events
>that should have auto forwarded were expired upon reception according to the
>printouts attached to the EAS logs. So that was the main problems. I did say
>that I felt the unit needed to be at the local studio location. The reason
>behind that was because I think the Barix boxes were cutting out, or were
>set at such a low bitrate that they had problems passing the FSK data from
>the LP1 and LP2 receivers to the remote ENDEC unit. It simply was very
>unreliable. Also the ENDEC was installed on the program feed coming from
>their remote location. If an EAS event occurred when they were using their
>"local studio" I did not see any interrupt unit to put the remote EAS ENDEC
>into the program line.
>
> >The Barix feeding the EAS decoder was set for MPEG2, 128 kbps stereo
> >(dual
>mono)-plenty of resolution for EAS. I have dozens of customers using the
>Barixes in this fashion with ZERO problems. It was tested many times by me
>and found to be relaible. Now, in fairness, I have no idea if things were
>changed after I left.
>
> >Again, as left by me, the program circuit ran though the EAS encoder
> >via it's
>external relay audio switch (this is a TFT unit, and they sell an external
>stereo audio switcher) from there it went to a 1:1 Tellabs repeat coil
>(transformer) and then straight into the Barix Instreamer that directly fed
>the transmitter site. All this was hard wired-there was NO way to remove the
>EAS from the program circuit.
>
> >When they use their local studio, they sent the audio back to the
> >control
>point in Boston.
>It was then mixed with spots, promos and PSAs and sent back DIRECTLY to the
>transmitter. There WAS no direct way to get audio from the local studio to
>the transmitter-EVERYTHING went through the control point in Boston. This
>was done deliberately. Your comment about no EAS while running local
>programs is just plain WRONG!
>
>As an ABIP inspector I try to be very fair and do a thorough job. In the
>last few years I've been doing ABIP inspection, I've received very few
>complaints. I'm not a nit picker. This was clearly a life safety issue. I
>take EAS very seriously.
>
>As far as Dana Puopolo's remark calling me a Moran I'm not even going to
>dignify a response to that. My qualifications as a Broadcast Engineer are
>known to many in the industry.
> >I'm sorry that I called you names. I regret it. BUT the fact is that
> >the way
>I set the unit up was 100% legal. Your telling them that was not legal (and
>in fairness  since I got it second hand from them they could be wrong) was
>wrong, off base and made ME look like a moron in their eyes!
> >Finally, whay didn't you simply CALL ME? I would have gladly explained
> >what
>was going on. Your (incorrect) assumptions about how things were wired not
>only made both of us look like idiots, but also cost my (former, thanks to
>this) client over $5000.00-to fix a problem that didn't exist!
>-D
>
>Matt Lightner - President
>Lightner Electronics Inc.
>www.LightnerElectronics.com
>Engineering Consultant/PA EAS Technical Chairman Pennsylvania Association of
>Broadcasters www.PAB.org <http://www.pab.org/>
>(814)-239-8323 Phone
>(814)-239-8402 Fax
>