[EAS] Yesterday's CAP RWT

[Ed Czarnecki]

The FCC's decisions on converter boxes/intermediary devices is more
"cautionary" than anything else.  They basically stated that while the FCC
has its concerns about converter boxes, they heed the opinions of those who
filed comments that EAS Participants should decide for themselves (citing
Verizon's comment on that point).

Yet, in paragraph 74 of the 5th R&O, the FCC states:

74 .... "However, because we also require that EAS Participants utilize the
enhanced text in a CAP message to provide a visual display, as set forth in
section 3.6 of the ECIG Implementation Guide, we will require that any
intermediary devices provide such functionality by June 30, 2015, which is
three years from the June 30, 2012, deadline for overall CAP compliance."

So, it is not a sunset, at Darryl noted.  It is, however, a device
requirement to support certain future functionality.  The fine point here is
that the FCC does not distinguish by type of EAS Participant (radio vs.
TV).  It simply states that the device must have that functionality by June
2015.

But, a broader point is made just a few sentences earlier:

"74.  Accordingly, we will allow EAS Participants to meet the CAP-related
obligations we adopt in this order by using intermediary devices in tandem
with their existing legacy EAS equipment, provided that such configuration
can comply with the certification requirements detailed in section IV.C of
this order, as well as with any applicable Part 11 requirements we may adopt
in the future."

So, right there the FCC is warning that its possible there could be
additional requirements beyond the .  What could the FCC adopt that would
challenge an intermediary device?  I could postulate several things that
potentially impact intermediary devices in the video area (cable TV, IPTV,
broadcast TV).  Not too sure about the radio segment, though.
Hypothetically, what if they create new event codes (problematic for
unsupported legacy EAS devices).  Or change an existing efent code
requirement (how about giving NPT unlimited audio capability, so they could
do an EAN-like test, without the scary EAN part).  Again, that would require
a firmware change in the legacy device, not so great for unsupported
equipment.  

Not saying the FCC is contemplating anything like this at present (?).  Just
pointing out that while the FCC was not establishing a "sunset", they were
certainly getting on the record a caveat emptor of sorts (or perhaps, more
gently, a "let the buyer be aware" ... "emptor conscii sint") ... as well as
perhaps "fabrica conscii sint" (let the manufacturer be aware). 

YMMV

Edward Czarnecki, Ph.D.
  Senior Director - Strategy, Development & Regulatory Affairs
100 Housel Ave. | Lyndonville | NY | 14098

www.monroe-electronics.com
www.digitalalertsystems.com

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

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

> Mike,
>
> There is no "sunset" on CAP converters, and it is incorrect that "the 
> matter will be self resolving when the use of converters is no longer 
> allowed and everyone must have CAP in a self-contained device." CAP 
> converters may continue to be used indefinitely as long as they meet 
> the requirements of 47CFR11.56(b).
>

>
> Regards,
> Darryl E.Parker