[EAS] My article

[Richard Rudman]

Hi, Tom (and all the others who have joined the list):

Thanks for signing up!

Thanks for your comments on the article, Tom. I was very careful to put in the phrase "at this time" when I talked about CAP converters. We are still in a mode of waiting for answers for many questions about new EAS devices, including how CAP Converters and original EAS devices will work together. You could be right.

A couple of points. The FEMA contractor is performing conformance testing for CAP compliance. I do not think this includes certification for Part 11 compliance. 

I have not seen any reference yet to an FCC certification process for Part 11 compliance for new devices. If the FCC announces a certification process, how can they do so without adopting revisions to Part 11? Since Part 11 has not been revised yet...

So, it would seem to me that manufacturers might be put in a classic "chicken/egg" situation if the FCC adds on to the already announced September 2011 time when the sand in the 360 day clock runs out. In their November 18 FCC statement, they left themselves some wiggle room to put more sand in the clock.

The BWWG Petition raised the issue of FCC certification in addition to FEMA conformance testing.

If the Petition (and article) do nothing more than cause all stakeholders in the process including the FCC and FEMA to not rush the process, we stand a better chance for a better outcome.

Finally, I am hoping that discussions on this list where stakeholders like you can openly raise issues, challenge assumptions, and offer new ideas will help us all implement a better public warning system. 

Richard Rudman

On Dec 3, 2010, at 5:36 AM, Tom Taggart wrote:

> That's probably true of any supposed "CAP compliant" device.
> I am not sure whether the manufacturers even know if their
> units passed the FEMA lab tests yet.  Jim Gorman hadn't
> heard anything when I talked to him at the radio show in
> September.
> 

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