[EAS] Part 11 NPRM

[Dave Kline]

Mr. Miller,

You're comments are pretty much "spot on."

My Opinion...
Life is too short to put a lot of stock in to what you read in an NPRM.
Unless, of course you intend to formally respond to the FCC.
I, personally am not so inclined. I'll wait for the part 11 rewrite  
and work from their.

Fact...
The FCC has stated that they require states to have a state plan at  
least going back to the beginning of EAS circa 1997.

My Opinion...
The FCC EAS handbook, is too generalized to account for differing  
conditions in locations around the country.
So they mandated that a state must have a plan. (EAS would not have a  
prayer of functioning without a state plan.)
Many states were forced to quickly throw something together to get  
approved and hopefully make it actually work later.
Some states did not have a plan in place for quit a while after EAS  
became the law of the land.
The FCC did not tell anyone who was responsible for writing such a  
plan. And by default it fell to whoever stepped up to do it.
They also did not really seem to care who wrote it or if one was  
written. They do not have jurisdiction over any such groups or even  
states.
It was a lot of barking but with no bite.
Since then FEMA has kind of stepped in to work with states in  
developing plans. They do have some sway with SECC's.
But as far as an enforceable law? It meant nothing.
The only thing that has made the EAS work, are SECC's, state  
broadcaster associations, the SBE and the engineer or other committed  
person at the local stations.
Those who have stepped up in the past, will likely be the one's who do  
so again.

Dave
************************************************
Dave Kline   UNO-TV / KVNO
University of Nebraska at Omaha
6001 Dodge St. Omaha, NE  68182  CPACS 200
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On May 31, 2011, at 10:35 AM, Wayne R. Miller wrote:

>Hello all along the EAS network.....
>
>I spent part of the Holiday weekend trying to make some sense of  
>this with no luck.  It asks more questions than it answers and does  
>not get us one step closer to any solution.  I can best describe it  
>as an "EAS meltdown" (thanks to Warren Shulz for the quote).
>
>Taking a simple system that does work and complicating it to the  
>point where it won't is not a solution.  I am reminded of the  
>definition of a camel: a horse designed by a government committee.