[EAS] Yesterday's CAP RWT

[Darryl Parker]

Mike,

In 47CFR11.56(b) the Commission codified what they decided in the 5th Report and Order in Paragraph 75 and 76:

"75. We recognize that it will likely be technically unfeasible for universal intermediary devices
(and possibly some component intermediary devices), as well as the legacy EAS devices with which they
are configured to meet this requirement, which means that such equipment would have to be replaced.
While we acknowledge that there may be costs involved with replacing non-compliant equipment, we do
not believe that such costs are beyond those that EAS Participants may expect in the normal course of
business, particularly as much of the underlying legacy equipment upon which intermediate devices
depend is old and will soon need to be replaced.237 Although no commenters discussed specific figures
for equipment costs, we believe that the approximately three and one half-year window we are providing
for intermediary device users is sufficient to allow EAS Participants to finish depreciating and then workarounds to allow intermediate devices to become compliant with our rules. Among the benefits that
CAP-compliant equipment will bring is an EAS that is more accessible to all Americans, including
Americans with disabilities, who will directly benefit from this new requirement.238 We agree with the
many commenters that argued that using CAP's capacity for enhanced text would, among other things,
help harmonize the EAS rules with the requirements of section 79.2,239 and thus conclude that requiring
intermediate equipment to comply with these rules by June 30, 2015 is justified.

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. Whereas the record
indicates that integrated CAP-capable EAS devices are easily updateable to evolve with potential changes
to the CAP standard and any resulting Part 11 requirements, intermediary devices and legacy EAS
equipment may not be so adaptive. Accordingly, there is no guarantee that intermediary or legacy EAS
devices will not have to be replaced earlier than integrated CAP-capable EAS devices."

Regards,
Darryl E.Parker
TFT, Inc.
San Jose, California 95131-1708 USA
Tel: (1) 408-943-9323, Extension 223
www.TFTInc.com

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

Then what did the FCC put a sunset on in the last R&O?