[EAS] EAS Ignorance

[Adrienne Abbott]

Even the Part 11 rules are less than clear about how Low Power stations
should operate their decoder-only EAS equipment. Yes, the rules say the
stations only need to read the RMT test script, but are the stations really
obliged to follow the RMT schedule for their Operational Area, reading the
test script when the station receives the RMT from a monitored source? Or
can they follow their own schedule and read an RMT message once a month?
Where do the stations get the script? Must they use the same script used for
the Operational Area RMT? How do the LP stations get a copy of the script
for the RMT? 

Many Low Power stations are automated, with no staff available to read the
RMT message when the test is sent. Is it enough for the station to schedule
a spot with the pre-recorded test script for the same hour as the RMT? Or
must the RMT be a "live read"? Must they even follow the FCC's
daytime/nighttime month pattern?

Like everything else, the FCC made a number of assumptions when they
developed the Low Power programs for both radio and TV. The first assumption
was that these would not only be community-oriented stations filling a niche
left empty by the large, commercial operations, these stations would also be
staffed during their broadcast hours by volunteers and students. As you and
I know, that's not how it works...

Much FCC law is a matter of interpretation, based on enforcement actions.
You can learn a lot by reading the NOV's and there really aren't many cases
involving EAS and Low Power stations. Rather than become part of a legal
precedent, many Low Power stations--at least the ones with we have here in
Nevada--opt for the full EAS encoder/decoder and operate according to the
rules for full power stations. The extra couple hundred bucks is cheaper
than hiring air staff and way cheaper than an FCC attorney. Smart move. 

The few who are running decoder-only equipment have never contacted the SECC
for information on running RMT's...not so much!

Adrienne Abbott
Nevada EAS Chair
NVBA  ABIP  Inspector

Sean Donelan asked: 
Just last week, I needed to ask several manufacturers how "decoder-only"
operations worked.  Even the brand-new EAS Operating Handbook takes some
shortcuts with some of the more obscure requirements for decoder-only
facilities. And how manufacturers have actually built certified EAS