[EAS] Class D origination

[jim at jimpollock.net]

>From: "Adrienne Abbott" <nevadaeas at charter.net >

>Yes, according to Part 11, in 11.61 Tests of EAS procedures--they should
>send or originate an RWT.
>(2) Required Weekly Tests:

>(i) EAS Header Codes and EOM Codes:

>(A) Analog and digital AM, FM, and TV broadcast stations
>must conduct tests of the EAS header and EOM codes at least once a week at
>random days and times.

>And I stand corrected. According to the table in Part 11.11, LPFM equipment
>should be able to generate or encode, the dual tones.
>Adrienne

I share in Adrienne Abbott's quandry.

I have been following the EAS saga as a loyal reader via EAS Digest for quite a while.
My interest is with an LPFM client.

FCC part 11.11 is not 100% in sync with 11.51

Part 11.11 The table says you need an EAS encoder (LPFM)
Part 11.51 The text says that you don't.

-- OK which is it?

For me, it opens a gray area for an FCC inspector to make the decision. Yikes.

After being sure that LPFM was exempt from EAS encoders; now, I am not so sure.

Also FCC part 801, which cites all part 73 regs that apply to LPFM, does not cite
or 73.3549 (Filing for an extension on EAS equipment.)

It comes down to economics; which is cheaper?

1. The differential cost between a decode only and a fully featured EAS.
This should be a SMOP--Simple Matter of Programming. The PC boards
most likely are stuffed with the same parts; it is easier to manage because parts are cheap.
Configuration management is a headache. Been there.
2. Lawyer consultation fees.
3. An FCC Fine for having your coin toss come up as "tails."
As Homer Simpson would say; "Doh!"

For me, I will sleep better with choice #1.

Jim

James W. Pollock, PE