[EAS] National EAS Test Forward

[Sean Donelan]

On Mon, 8 Aug 2016, Barry Mishkind wrote:
> At 06:02 PM 8/8/2016, Mike McCarthy wrote:
>> Has the question on timing within the NPT message to start forwarding been
>> answered?
>
>        11.54

That's why lawyers make money.  If you read the justification and analysis 
in the sixth report and order, the FCC said it was not requiring more 
expensive changes to fully emulate the EAN.

https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-60A1.pdf

I would argue the FCC's changes and the rest of its analysis doesn't
require changing a NPT to emulate the "live" EAN requirement (and other
things like unlimited length, pre-empting other events, etc.)  The FCC 
analysis was about the 15/60 minute delay.  The FCC explicitely considered
that other standards and proprietary protocol changes which would be
required to emulate the EAN, and rejected the need to make those changes
for the NPT (paragraph 22 of 6th R&O).

I think a good faith interpretation is "immediately" upon receipt of the 
NPT event code means without a 15/60 minute delay (i.e. zero hold-off). 
But it does not require that the NPT must be streamed "live" if 
that requires extensive changes to other standards and proprietary 
protocols found in cable systems, wireline, satellite, etc.

This may just be one of those things that is different between how 
broadcaster systems work and how other participants systems work.

But my opinion is meaningless.  Consult an appropriate legal advisory 
licensed to practice in your state.