[EAS] {Disarmed} Re: Authority to form State Emerg. Comm. Committees

[Gary Timm]

Rod, et al,
In my comments to the Commission in the informal request for input on the forthcoming rule changes, I pointed out that I found only two references to the SECC in the Part 11 rules.  One is the section cited below by Richard that the SECC sets the RMT schedule.  The other is that entities not required to participate in EAS, such as satellite providers, should consult the SECC for guidance if they wish to voluntarily participate in a state's EAS.  You can find the references easily by doing a word search in the rules.
 
I pointed out in my filing these SECC references, but the lack of anything stating the origin, composition, or authority of the SECC in Part 11 - and stated this is needed.
 
As Adrienne pointed out, we old-timers actually got a letter from the FCC appointing us as State Chairs.  At one point we even got a wallet ID card.  The defacto process was for a person to volunteer to FCC to be a State Chair, the FCC then sent out an appointment letter.  But again, this is documented nowhere I know of in print.
 
So Rod, if you are looking for a citation as to where the SECC gets its authority and who should be on it - that does not exist to my knowledge.  You can certainly direct people to the FCC EAS webpage where there is a link to the State EAS Chairs where the Chair will be listed.  That is about the only thing in print giving FCC support to anyone in the state charged with overseeing the EAS.
 
I hope in the forthcoming NPRM on rule changes we will see progress on this issue.  If not, there is opportunity to submit comments.
 
Gary Timm

--- On Wed, 3/2/11, Adrienne Abbott <nevadaeas at charter.net> wrote:


From: Adrienne Abbott <nevadaeas at charter.net>
Subject: Re: [EAS] Authority to form State Emerg. Comm. Committees
To: "'The EAS Forum - accurate & up-to-date EAS information'" <eas at radiolists.net>
Date: Wednesday, March 2, 2011, 5:43 PM


Remember that we also received letters of appointment from the FCC
designating us as SECC Chairs.
Adrienne

"Radio burps, it cries, it needs to be fed all the time, it requires
constant attention, but we love it." Jim Aaron WGLN 


-----Original Message-----
From: eas-bounces at radiolists.net [mailto:eas-bounces at radiolists.net] On
Behalf Of Richard Rudman
Sent: Wednesday, March 02, 2011 3:33 PM
To: The EAS Forum - accurate & up-to-date EAS information
Subject: Re: [EAS] Authority to form State Emerg. Comm. Committees

State Emergency Communications Committees are indeed mentioned in Part
11(a)(1)(v). I have copied 11.61 below in its entirety with emphasis on the
SECC cite.

But, that's the only place, and there is no direct mention of Local
Committees. You could certainly infer from what is said in 11(a)(1)(v) that
local committees should be a part of the process.

Many of us feel that more should be said about SECC's and LECC's in a
revised Part 11 because we know where you have a good partnership behind
SECC's and LECC's, you are more likely to have better overall results for
EAS tests and events. Washington State is my current pick for one place
doing it right.

Regards,

Richard Rudman
CA SECC Vice Chair
BWWG 

11.61 Tests of EAS procedures.
(a) Tests shall be made at regular intervals as indicated in paragraphs
(a)(1) and (a)(2) of this section. Additional tests
may be performed anytime. EAS activations and special tests may be performed
in lieu of required tests as specified in paragraph
(a)(4) of this section. All tests will conform with the procedures in the
EAS Operating Handbook.
(1) Required Monthly Tests of the EAS header codes, Attention Signal, Test
Script and EOM code.
(i) Effective January 1, 1997, AM, FM and TV statio ns.
(ii) Effective October 1, 2002, cable systems with fewer than 5,000
subscribers per headend.
(iii) Effective December 31, 1998, cable systems with 10,000 or more
subscribers; and effective October 1, 2002, cable
systems serving 5,000 or more, but less than 10,000 subscribers per headend.
(iv) Effective October 1, 2002, all wireless cable systems.
(v) Tests in odd numbered months shall occur between 8:30 a.m. and local
sunset. Tests in even numbered months shall
occur between local sunset and 8:30 a.m. They will originate from Local or
State Primary sources. The time and script content will
be developed by State Emergency Communications Committees in cooperation
with affected broadcast stations, cable systems,
wireless cable systems, and other part icipants. Script content may be in
the primary language of the broadcast station or cable system.
These monthly tests must be transmitted within 60 minutes of receipt by
broadcast stations and cable systems and wireless cable
systems in an EAS Local Area or State. Class D non-commercial educational FM
and LPTV stations are required to transmit only the
test script.