[EAS] Yesterday's CAP RWT

[Dave Turnmire]

On 10/15/2012 2:03 PM, Ed Czarnecki wrote:

>...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.
>...

I'm not an attorney, but I'm not sure that is entirely correct. 

>11.56:
>(b) EAS Participants may comply with the requirements of this section by deploying an Intermediary Device. If an EAS Participant elects to meet the requirements of this section by deploying an Intermediary Device, it shall be required to construct visual messages from CAP-formatted EAS messages in accordance with § 3.6 of the "ECIG Recommendations for a CAP EAS Implementation Guide, Version 1.0" (May 17, 2010), as set forth in§§ 11.51(d), (g)(3), (h)(3), and (j)(2)of this part, on or by June 30, 2015.
Note the specific 11.51 references.  (d) is for "Analog and digital television broadcast stations", (g) is for "Analog cable systems and digital cable systems", as is (h) (just subscriber # difference).  And (j) is for "DBS providers ".  So by my reading, all the references to meeting the visual message construction format are for non-radio broadcasters.  Who knows what is in the hearts of the FCC, but based upon the wording, I would think a "reasonable man" might interpret that requirement (and the associated July 2015 deadline) as not being applicable to radio broadcasters.  To say nothing of common sense.

Of course, that doesn't change the FCC's wider point about intermediate devices being particularly exposed to future changes in Part 11.  But I'm not seeing a requirement for radio broadcasters to abandon intermediary devices after July 2015 in the CURRENT FCC rules.

Dave