[BC] CAP converter sharing?

[Kyle Magrill]

Well, in reality, the situation is somewhat more complicated.  
We have a time-shared channel where three LPFM 
licensees cooperated and put up a common transmitter site.  
They share a transmitter and audio path.  There is one satellite-delivered 
(fairly SLOW) Internet connection, one automation computer, 
one EAS Encoder/Decoder, one audio processor and one 
transmitter.  Now, to be fair, we didn't consult the FCC about 
needing three EAS boxes, or not.  Maybe the letter of the law 
would indicate that they must have 3 but it would have been 
totally redundant and when alerts come along, each box would 
try to insert itself on the air with only the last in the chain actually 
going live.  Of course, it would have been possible to rig an audio 
switcher to a clock to ensure that only the correct station's EAS 
message was transmitted, when that station was technically on the air 
and the others are silent, but why?   It's very wasteful and unnecessarily 
complicated.  Alternately, being LPFMs, they could go silent during alerts, 
so it wouldn't matter how many boxes in series switched off the audio.  
What a waste that would have been and they all felt that they had a 
resposibility & desire to participate in EAS.  So, we're already working in a 
grey area, but I couldn't think of a less wasteful solution for these guys 
other than to simply treat the single airchain as if it was really only one 
station (which for all practical purposes, it is since only one station can 
be on the air at a time).  

Now, added to the mix are two other LPFM stations, each with 
their own EAS boxes.  One is a decoder only and the other is an 
encoder/decoder.  Interestingly, the question of sharing an ISP & 
router is far from theoretical in this case.  That's exacrtly the situation 
that already exists. These other two stations have limited Internet 
connections since they all share the satellite account owned by 
the timeshared LPFM station.  The timeshare guys will only share their 
satellite with the other two only at certain hours of the day.  The 
stations get along fine, but the timeshared station uses the Internet 
connection pretty fully and they don't want to risk letting the other 
stations use too much capacity and possibly crashing one of the 
time-shared stations' streams (which has happened).  The timeshared 
station will agree to share a CAP converter since one Internet connection 
is necessary anyway and the output of the CAP converter is only 
audio.  Even if the other two LPFM stations got their own CAP 
converters, they would have no Internet connection to feed it, so 
what would be the purpose of the CAP converter without such a 
connection?  By sharing one CAP converter, all of the stations can 
split the cost three ways making it much less of a strain for them 
to put a working system together.     

I'm looking at the CAP converter as just another audio source
that feeds the EAS, not the actual EAS itself.   From that perspective, 
I think sharing one converter can be justified.  Do the rules specifically 
bar this?  What would the basis for the FCC requiring individual CAP 
converters at a common site?  

                                      
*********** You Wrote*********

This begs the question - could Kyle's gaggle of
LPFM stations share one ISP account?  How about
sharing the same router?  How about sharing the
same CAP converter, if they all have their own
encoder/decoders? 

"Not so grey.  We had a discussion about this
months back and the FCC wants
everyone to have his/her own units for each owner
at a common site.
Steve Lewis"