[EAS] RMT

[Dave Kline]

So you ARE a true LPFM as described in 
Part 73, Subpart G--Low Power FM Broadcast Stations (LPFM) 73.801 thru 73.881.
That helps.

Part 11.11(b) Says that if you are an LPFM as described in 73.811 that you are not required to comply with Part 11.32
Part 11.32 Describes the EAS encoder used to send alerts.

This then would seem to say that you are exempt from having to relay or originate EAS alerts.
I've cited the rules that I found to support this. There may be other rules that apply in your case and I encourage you to look into it a bit further than did I.

If an alert comes in while you are off the air, you might be required to enter it in the station log, but you might not need to do so. 
I hope someone will jump in with that clarification and also confirm or correct any of my observations.

It seems also that there is nothing that says you cannot enter it in your log even if not required to do so.
But as many others will point out... you should not make log entries that are not required. 
It might get you in trouble for something related or unrelated to the entry.

As Joe Friday would say: "Just the facts ma'am."
And it seems that the facts are that you do not have to encode (send or relay) EAS alerts. 

We all have our opinions on this list and try to help as best we can.
However, anything posted here should not be taken as be hard fact.
There are always gray areas.
Not having to originate or relay any alerts would certainly make your job easier and also hold other advantages for your station.
Given those plus' and if you are uncomfortable with any advice you get (I'm always suspect) or with your own take on the rules it might be worth getting a ruling from your (or a) legal council who specializes in FCC law.

Coffee Time!
Good Luck
Dave
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Dave Kline   UNO-TV / KVNO
University of Nebraska at Omaha
6001 Dodge St. Omaha, NE  68182  CPACS 200