[EAS] [sbe-eas] IPAWS OPEN failure

[David Turnmire]

On 9/24/2012 2:04 PM, Adrienne Abbott wrote:
> Part 11 also requires us to maintain our EAS equipment in a constant state of readiness and to document any time it's out of service. If there's a failure in the over the air equipment and it doesn't receive a monitored source you document that it was taken out of service for repairs and when it went back in service, along with a note about any tests or activations that were missed.  Part 11 does not specify a minimum down time for this documentation requirement and in the past with the legacy equipment you could have a receiver down for seven days before anyone knew there was a problem. ...
But... it doesn't require us to maintain SOMEONE ELSE's equipment in a 
constant state of readiness... such as the LP.  I see no way that we are 
responsible for maintaining records of FEMA's problems, nor the wider 
internet.  On the other hand, if we lose internet access on a local 
level due to our own equipment failure (hardware or software... or 
failure to pay the ISP bill), we should likely log that as it is 
arguably comparable to having an EAS monitored source receiver failure, 
etc.  Maybe log a local internet outage (if we knew about it) that was 
our ISP's fault.  Beyond that...hard for me to see a legal obligation 
under Part 11.  Of course... I'm not an attorney...

Dave