[EAS] Action Required by April 23

[Ed Czarnecki]

Richard - just to be precise about my comments, the FCC can deign to
regulate activities on equipment requiring an FCC-certification, and at
sites coming under FCC jurisdiction.  NWS does not come under FCC
jurisdiction.  Nor, ostensibly, does a state or local emergency management
agency.

The NWS example is that of TTS being generated by an entity outside of FCC
jurisdiction, on equipment/SW not ostensibly subject to FCC certification.
Similarly, our DasEOC CAP originator provides the option of generated a TTS
message from the Originator (two states and a number of counties have
adopted the DasEOC already).  Both approaches are consistent with the new
FCC rule.

In short, where TTS comes from the source (the Originator), TTS is kosher.
TTS locally generated on an EAS device at the remote end (EAS Participant)
is not kosher.

The FCC rules define what the device must do (and not do) at the EAS
Participant site.  However, the rules do not explicitly regulate the
originator (as that is arguably outside the FCC's immediate authority,
though this does have the effect of reverse or implicit regulation).

At Monroe/DAS, we are hopeful that the FCC will amend its position, to allow
- at a minimum - TTS to be used as a backup in case the Originator audio
file is missing or damaged.  However, while we are also hopeful that the FCC
will eventually amend its position on TTS, we don't feel it is likely that
such a rule change would be affected by April 23rd (13 days hence).  

For this reason, we are advising users to make this settings adjustment,
until and unless the FCC changes its rule prohibiting use of TTS capability
on an FCC-certified EAS device ... at an EAS site ... for the purposes of an
EAS message.

We are also advising the DASDEC users affect this settings change before the
NAB conference, simply because things might get lost in the shuffle with the
various conferences coming up (PREC+NAB)...

Ed

-----Original Message-----
From: eas-bounces at radiolists.net [mailto:eas-bounces at radiolists.net] On
Behalf Of Richard_Rudman

While Ed is correct that the FCC can regulate almost anything they decide to
regulate, I do not see how they could invoke a total text-to-speech
prohibition.

For one thing, that would mean that we would all have to stop running NOAA
Weather Radio messages.

I am optimistic that the FCC will listen to the growing tide of voices,
including many in the emergency management community, that have asked the
FCC to lift their TTS prohibition.

As we said in our filing, "The BWWG is asking the Commission to not to let
the goal of the perfect stand in the way of a clear, present and immediate
need for the possible."

Richard 

On Apr 10, 2012, at 9:19 AM, Ed Czarnecki wrote:

> Adrienne - I think that is a bit of a gray area. The FCC can, of course,
regulate just about anything they like on an FCC certified unit.

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