[EAS] Satellators and EAS

[Dan Peek]

My boss got this from our attorney, but I'm still having questions.
 
1. Will Hossein's word to the attorney hold up to the enforcement bureau?
2. In the old days, we were allowed to only pass the EAN and presumably RMT from headquarters. (I got Bonnie Gaye to say that for me) Recently I heard that wasn't true any more
3. If this is true for EAS, will it apply to CAP as well so that one CAP machine can service the network of translators?
 
I finally have an answer for you on the EAS question, and it is good news.  I spoke to Hossein Hashemzadeh about this issue generally and discovered something I did not know before.  He said that the FCC now considers LPTV stations to be translators (and therefore exempt from EAS requirements) if they are merely retransmitting programmingfrom any source, and not originating any programming on their own.  I could not have known this because the FCC rule that defines translators states that a translator is a station that retransmits the signals of "a television broadcast station."  I mentioned this to Hossein and he said that "interpretation" is "old school."  He said that so long as the station is doing nothing other than retransmitting satellite programming and not originating any programming of its own, the FCC (i.e. Hossein) considers that to be a translator.   And translators are exempt from EAS requirements.
 
I told Hossein that I believe that all of these stations are licensed as LPTV stations and asked whether we should submit letters converting them to translators.  He said that would be a good idea because, as translators, they would also be exempt from having to file FCC Ownership Reports!