[EAS] Coastline/Marine - Mandatory or Voluntary

[ray at electronicstheory.com]

I am an Engineer, and not a Lawyer, so please forgive my ignorance in this area
(esp. Legal)

I was asked a question to which I do not know the answer, and I think it
important to bounce it around the group - as it may affect others:

According to 47 CFR 11.31, "EAS Participants that install or replace their EAS
equipment after February 1, 2004, must install equipment that is capable of
receiving and transmitting these location codes"

The codes they are referring to are coastine/marine codes like 97xxx for Lake
Erie, etc.

Am I understanding that the equipment must be technically capable of
transmitting the codes if they were so programmed, or should the equipment by
mandate be actually programmed to transmit the coastline codes?

I ask, because in the section above it, it states, "Effective May 16,2002,
analog radio and television broadcast stations.... may upgrade their...equipment
to add these marine area codes on a voluntary basis"

So what I'm asking in a nutshell is:

While the equipment must be technically capable of adding the codes - is it
required, or voluntary for the individual stations to actually add the codes?

This may affect how some of us put FIPS codes into our boxes...