[EAS] New EAS operating handbook...odd text...

[Sean Donelan]

On Tue, 23 Aug 2016, Mike McCarthy wrote:
> Which begs the question, how much editing can we (the station) do to tidy
> up these kinds of typos's?  If the FCC's goal is to allow complete
> handbook customization, then I would expect there would be leeway given to
> clean up these types of statements which have no applicability to a given
> licensee.

When FCC asked for comments from the public about the proposed EAS 
Operational Handbook, my advice to the FCC was eliminate the rule 11.15.

A majority of EAS facilities operate their EAS equipment in "automatic" 
mode, and the facility staff should do nothing.  There isn't a need for
"operating instructions" in most cases.  The FCC EAS Operating Handbook is 
just a waste of time for most EAS participants, and fodder for fines by 
the FCC Enforcement Bureau.

The exceptions are staffed EAS "primary" facilities (SP, LP-1, LP-2) and
facilities operating in "manual" mode. Staff at these facilities should 
have written operating procedures.  The problem is the operating 
procedures for a primary EAS participant are likely more complicated,
require a lot more customization than the CSIRC and FCC handbooks.

If I was advising the FCC, I suggested it spend its resources on an EAS 
engineering handbook for the people who install and maintain EAS 
equipment. The EAS engineering handbook could have an sample "operating 
procedure" appendix, which the EAS engineer may use as a template or 
create a staff operating procudure.

In most cases, the staff operating procedure is a single sheet of 
paper taped to the front of the EAS encoder/decoder that says "DO NOT 
TOUCH, in case of a problem call the station engineer at ____________."