[EAS] Class D station origination

[Adrienne Abbott]

What do they mean by "originate"? Why would they originate a test? They
aren't the LP station. They are exempt from RWT's because their equipment
won't generate the tones. If they have the TFT decoder, it will rebroadcast
the RMT for them. If they have other EAS equipment, they are supposed to
read the RMT script without the tones. What else is there? What kind of CAP
equipment are they going to purchase? It may be time for them to go with a
complete EAS Encoder Decoder, especially if the station is running on
automation. 
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 Lowell Kiesow

The current rules are pretty clear that they do not have to originate tests.
Of course, we don't know what changes may occur in the near future.  Here is
the section from Part 11.51..........
 
(e) Analog class D non-commercial educational FM stations as defined in
   § 73.506 of this chapter, digital class D non-commercial educational FM
   stations, analog Low Power FM (LPFM) stations as defined in § § 73.811
   and 73.853 of this chapter, digital LPFM stations, analog low power TV
   (LPTV) stations as defined in § 74.701(f) of this chapter, and digital
   LPTV stations as defined in § 74.701(k) of this chapter are not
   required to have equipment capable of generating the EAS codes and
   Attention Signal specified in § 11.31.

My take on the rules is that if they ever run un-attended, then they need to
have a full decoder/encoder installed in the program line.  It's easier to
do that than it is to always have an operator on duty to sign the station
off in the event of an EAN.

 
On Thu, Sep 22, 2011 at 8:52 AM, Ellis, Andrew R <ellis at kcbs.com> wrote:
>Ladies and Gentlemen,

>Not sure why they called ME, but a local Class D FM at a college asked
>if they're required to originate EAS tests.  They monitor but haven't been
>originating.

>Whatever is said here, I'll attach the usual disclaimer: "Contact your
>firm's communication attorney."

>Anyone?  Buehler?

>Many thanks,

>Andrew R. Ellis, CPBE
>KCBS/KLLC
>CBS Radio
>865 Battery St.
>San Francisco, CA 94111
>[cid:image001.jpg at 01CC7904.E42805C0]
>[cid:image002.jpg at 01CC7904.E42805C0]