[BC] EAS 911-D

[Mike McCarthy]

Kyle,

I would have the three licensees sharing the common transmission chain 
submit a request for a rules waiver to the FCC with regards to each 
licensee being required to have their own ENDEC system.  I agree three 
time shared LPFM's on tight budgets should be afforded that level of 
flexibility.

With that said, the licensees should be prepared for an answer they may 
not like....and the waiver may not come in time considering the deadline 
is only 5 days away.

With that said 2--  I don't have much sympathy for licensees crying 
poor.  A license carries privileges and responsibilities. If they're not 
able to meet those obligations, then maybe they should not be a 
licensee. Harsh, yes.  I make no bones about everyone playing on a level 
field.  But I do agree that because they share a common transmission 
chain and the FCC allows one transmitter for multiple uniquely owned 
stations on share time basis, the EAS could be considered an extension 
of that chain.

MM

On 6/25/2012 8:59 PM, Kyle Magrill wrote:
> Well, I don't know how three time-shared LPFMs with a
> common airchain would implement three decoders, or
> what the functional purpose of such an arrangement
> would be. Seems the rules are very poorly written
> if that's the case.
>
> *********** You Wrote: ***************
> FYI the rules are fairly clear on this.
>
> Only stations that are co-owned and co-located may
> use a single EAS encoder/decoder or EAS decoder only.
> This requirement does not apply to receivers of CAP converters.
> The outputs of receivers and CAP converters can be shared by
> stations in the same location whether or not they are co-owned.
>
> Regards,
> Darryl