[EAS] FCC Seeks Comment on Multilingual EAS

[Alan Kline]

I agree completely... I don't subscribe to the theory that "all 
regulation is bad", but *these* would be regulations that should never 
be written.

Aside from the obvious technical and logistical chaos that this would 
create with EAS, the NPRM appears to me to be looking at "emergency 
information" going beyond basic EAS into follow-up news programming. 
There, we hit a real slippery slope.

I once worked for a TV station in the SF Bay Area that regularly 
broadcasts in at least 7 languages, including English. Can you imagine 
the nightmares of just getting EAS messages on the air in all 7 
languages? To say nothing of the problem of translating EAS messages 
into Chinese, Japanese, and Korean script--and doing it almost 
instantly, and with 100% accuracy.

Then you get to the follow-up--even if translators were instantly 
available for the non-English languages (and they wouldn't be--some of 
our languages were covered by free-lancers or time brokers, and of 
course, EAS doesn't always happen during business hours)--who gets to 
decide which language goes first, how long they get, and when new 
information comes in, how do you interrupt the sequence and start over?

As a chief operator, how could I certify that *all* of our multi-lingual 
EAS tests, activations, and non-EAS emergency programming was accurate 
and compliant with the rules? (I barely made it through enough college 
Spanish to get my degree, and that was 30+ years ago...)

To me, requiring stations, which normally do not do extensive 
non-English programming, to do multi-lingual EAS and followup 
informational programming is a non-starter. The technical, logistical 
and financial burdens are just too much to demand of any station. And I 
think it's too much to demand that manufacturers of EAS gear spend their 
own money on R&D for such things, when it's unlikely that they would 
ever see a return on that investment.

Alan

On 3/12/2014 5:09 PM, Barry Mishkind wrote:
>          This should never get into the Rules ... it will
>          create havoc.