[EAS] Interpreting EAS Rules for Combined Stations

[Skinner, Jim]

All:

I find it interesting that the section below is in the FCC rules.  Are
there recommendations to change this section?

If it weren't there I would assume that one encoder could feed multiple
stations.  It does NOT say that a multi owner facility (like LMA) CAN
NOT use the same EAS Encoder, but that is perhaps implied?  

It is good to clarify this as stations are ordering their new CAP
compliant equipment.

Thanks

Jim Skinner
Nebraska SECC Chair 
 
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FCC Title 47 Vol.1 - Part11
Subpart D - Emergency Operations 
11.51 (l)    [lower case L]
(l) EAS Participants that are co-owned and co-located with a 
combined studio or control facility, (such as an AM and FM licensed to 
the same entity and at the same location or a cable headend serving more

than one system) may provide the EAS transmitting requirements contained

in this section for the combined stations or systems with one EAS
Encoder. The 
requirements of Sec. 11.32 must be met by the combined facility.
http://edocket.access.gpo.gov/cfr_2010/octqtr/47cfr11.51.htm
<http://edocket.access.gpo.gov/cfr_2010/octqtr/47cfr11.51.htm>