[EAS] Latest EAS NPRM Random Musings

[Rod Zeigler]

I view this latest round of proposed EAS changes as somewhat of a knee 
jerk reaction to both political pressures and exposure of a certain 
level of ineptitude in the Commission. First, the Commission is being 
pressured to enforce "inclusion" to satisfy the social justice 
crusaders. So, we have multilingual and challenged populations 
proposals. When the lack of Commission action on State Plans, that THEY 
requested, came to light we now have to try to figure out how to comment 
on something (State Plan Template) that we have not seen, and will not 
see until it is part of the rules. The other current craze at the FCC is 
that the Interweb is the be-all, do-all, and will solve everyone's 
problems overnight. (Which we all know is pure fantasy) Now we have to 
comment on security questions when we have no real idea of how secure, 
or of what scheme, the originated products security will be.

Why spend multiple $K to for an informational database? Because in the 
finest traditions of bureaucracy making work for others is a sign of 
productivity on the part of those assigning the work. I also suspect 
that like the online Public File, surfing for NAL's will become the duty 
of more than a few employees at the FCC.

Part 11 is a crazy quilt of regulations that were put together in no 
particular order. These proposals are a shotgun approach of the same 
disorder. Proposing to heap more responsibilities on SECC's, many of 
which are not even broadcast or cable related, underlines the fact that 
few, if any, in the FCC have the slightest inkling of what EAS does, is, 
or what is required to make the system actually work. A complete 
re-write of Part 11, organizing it into workable sub-parts, with a 
concise definition of the responsibilities, oversight, liabilities, 
general makeup, and even funding mechanisms of the SECC's is warranted.

Want to make EAS work for both the public, the disseminators, and the 
originators? Re-establish the National Alerting Committee under FEMA and 
get all of the players together in one place and hammer out some common 
sense (the real thing, not the political throw away word) rules and 
regulations. With multiple Federal agencies involved, as well as 
vendors, originators, disseminators, and special interest groups at the 
same table I know this is a bit of a pipe dream, but hope springs 
eternal that some good could come of such a gathering.

EAS is really a simple concept. Produce a product and for the most part 
let people pick and choose what they want to use. Yes, EAN's are the 
primary reason for the systems existence so make those mandatory. 
Simple, non-intrusive testing is a good idea as well so let's keep that. 
Beyond those two items let the marketplace decide.

PS...I have personally submitted comments to the Commission, and have 
authored responses from Nebraska to the National Assn. of State Bdcs't. 
Assn's. for inclusion in their comments as well. I strongly urge all of 
you to do the same.

-- 
R. V. Zeigler, Dir. of Eng.
Nebraska Rural Radio Assn.
Nebraska SECC Chairman
Nat'l. Emergency Bdcs't. Assn. Board Member
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