[EAS] The Real Cost of Converters

[Sean Donelan]

On Sun, 4 Mar 2012, wpio-fm wrote:
> Not so because when Amber Alerts were added for which there was no code
> (in original EAS) All stations had to replace their eproms for Amber
> with code it to interrupt programming.

Nope, no station needed to replace their eproms in existing EAS decoders.

Up to this point, all the changes FCC has made to Part 11 have always 
included a way for original pre-1997 EAS devices and software in use at 
stations to continue to be accepted without change.

All the 2002 event codes, including CAE (AMBER Alert), are still 
voluntary according to the FCC rules.  Your station management, state 
broadcaster association or local emergency officials may strongly 
encourage a station to participate in AMBER alerts, but that is not a 
FCC requirement.

New EAS devices sold must support the new event codes. But stations
did not need to upgrade their existing EAS equipment.  Likewise, 
stations did not need to upgraded their EAS equipment to handle the 
daylight savings time changes, and so on. One quasi-exception was EAS 
manufacturers provided free Y2K software PROM upgrades, but I wouldn't be 
surprised that some stations haven't installed those either.

Its not the role of the FCC to prevent people from making bad business 
decisions.  However, the FCC R&O does drop several anvils that it may no 
longer try to maintain backward compability with the original 1994 EAS 
protocol definition beyond June 30, 2015.

    "76. We also reiterate that the limited functionality of both
    intermediary devices and the legacy EAS devices with which they
    operate may render them unusually susceptible to changes in the
    Part 11 rules, such as development of new CAP functions and changes to
    the EAS codes."

The enhanced text requirement by June 30, 2015 is the first change which 
is not backwards compatible. Admittly, that change impacts video rather 
than audio. The R&O identifies in the footnotes several other deferred 
decisions which may not be backward compatible, such as a national 
location code, event code changes, and so on.  Depending on future 
decisions, those may or may not have an impact on use by radio stations of 
legacy EAS protocol and equipment.

You may want to ask your current EAS equipment manufacturer how much 
longer they will continue providing software updates to older EAS 
equipment in case of a non-backwards compatible changes.

In the end, its a business decision (in consultation with your legal
advisor). People have their opinion, but predicting the future is always 
difficult.  According to the published R&O, CAP intermediary devices are 
acceptable until at least June 30, 2015.

    "Moreover, the new rules permit, with certain limitations, EAS
    Participants to use intermediary devices to meet their CAP-related
    obligations. The approach taken in the Fifth Report and Order strikes
    a balance by allowing use of these devices by EAS Participants . many
    of whom are small or are non-commercial . but only to the extent such
    devices can comply with the rules adopted today by June 30, 2015. This
    is a significantly less costly alternative to requiring immediate
    compliance."

Who knows what will happen after June 30, 2015. In three years the FCC 
may extend the compliance date, change the requirement for radio stations,
meaning you will get even more life out of the equipment. Or CAP may just 
be a software module included in your station automation system and 
spending money on a dedicated CAP box would have been wasted.

On the other hand, in three years you may have to buy a new CAP box anyway 
because your legacy box no longer has manufacturer support and can't 
process new required protocol changes.  Or in three years, your EAS box 
may still be squawking EAS modem tones long after its decided that 
transmitting analog FSK is unnecessary to transmit the emergency 
audio message.  No one knows what the future may hold.