[EAS] Identifying the Test on air

[Dave Kline]

Alex,

Your interpretation and mine are quite different.
I assume you are the Chief Operator and as such you are responsible  
for compliance based upon your interpretation of FCC rules.
It is you vs them or me vs them. So each to his own.
I just wanted to present my interpretation for the consideration of  
fellow broadcasters, especially those who might be new to the business.

The FCC can be quite vague in their "letter of the law." The spirit,  
the interpretations, can be quite diverse. The issue comes down to  
defending one's position to the FCC if it becomes necessary.
I am sure we both can do that and likely you easier than I.
This is one of the areas where I differ from my normally very  
conservative take on the regs. I don't play fast and loose with  
federal agencies and do not feel I am doing so in this case.
The advantage is that I am taking the FCC's word (letter of the law)  
very literally. In doing so it affords a little more flexibility for  
the station.

 From part 11.61 Test of EAS procedures.
(2) Required Weekly Tests:
(i)(A) Analog and digital AM, FM, and TV broadcast stations must  
conduct tests of the EAS header and EOM codes at least once a week at  
random days and times.

Test are to AIR randomly.
There is nothing that says they can't be scheduled.
As long as you schedule them to AIR randomly.
For instance: For each week, you can pick (out of a hat or whatever) a  
random day.
(Two consecutive week's RWT could be on the same day of the week as  
long as the day was determined randomly.)
Then the same for the hour of that day. Schedule the test for some  
time during that hour.
Random day, random time.
I don't schedule our tests, I let the programming department do that.  
I just check to be sure there is no appearance of a non-random pattern.

There is also nothing that says there can be no more than seven days  
between tests. "once a week" not at intervals of seven or less days.
If you limited yourself to a max of seven days between weeklies this  
would have the affect of being less than random.
Suppose on week one you drew Monday and on week two you drew Thursday?
You would have selected both week's test days by a random draw but  
they would be 10 days apart.
To keep the max spacing to seven days you would have to throw out the  
second week's randomly drawn day and redraw until you hit one that was  
no later than Sunday.
This limits week number two's pool of available days and therefore is  
then not truly random.
The point of the regulation was for EAS tests to run under all  
conditions, at all times that might occur throughout the broadcast week.

This brings up the question of how a station defines a week.
One would do well to have this info documented.
For instance ours is defined as 00:00:00 Sunday thru 23:59:59 Saturday.
Doing so allows you to schedule randomly, or at least not have the  
appearance of a non-random pattern.
This allows full randomization because in week one you can run the  
test on any day of your "EAS Week". Likewise for week two and all weeks.
Somewhere back in the cobweb infested parts of my brain I recall a  
station being cited for changing how it defined an EAS week to cover  
up that it did not air a test one week.
(Maybe someone can help me out with that?)

Anyway, that's my side of the story.

Thanks Alex and everyone else.
I love these discussions.

Dave

************************************************
Dave Kline   UNO-TV / KVNO
University of Nebraska at Omaha
6001 Dodge St. Omaha, NE  68182  CPACS 200
************************************************

On Jun 14, 2011, at 3:15 PM, Alex Hartman wrote:

> Don't know that i'd go around admitting that you schedule your EAS  
> tests...  Remember, they're supposed to be randomly positioned no  
> more than 7 days apart. ;)
>
> (Yes, i know everyone schedules them...)
>
> --
> Alex Hartman
>
> On Tue, Jun 14, 2011 at 12:03 PM, Bill Ruck <ruck at lns.com> wrote:
>> Why?
>
>> I had traffic schedule the EAS RWT between commercials.  Less
>> disruption that way.
>
>> Bill Ruck
>> Curmudgeon
>> San Francisco
>
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