[EAS] Source of the "scary" text in Suffolk Co

[Sean Donelan]

On Thu, 8 Sep 2016, Ed Czarnecki wrote:
> However, I'm more cautious about national event codes though both NPT and
> EAN).  There is a black and white rule on "immediacy" here.  OK, not quite
> black and white ... perhaps dark-gray to light-gray...  Would a 2-second,
> 1-second or less delay be not "immediate" enough?  A rule clarification, as
> you suggest, might be desirable in these cases, but hopefully would not
> result in a major proceeding.  Again, what is "immediately" upon receipt?
> Are a few moments to buffer and now to double check a CAP source allowable?
> How many "moments"?

Putting on my ANSI/ISO standards lawyer imaginary hat (I am not a lawyer):

In 1994, when EAS was first specified by the FCC, it included manual 
operation by a human operator.  In 1994, it also still included the 
infamous Red Envelope. In 1994, the term "immediate" must have been long 
enough for a human to open the red envelope, and check the authenticator 
word.

The FCC eliminated the red envelope, but kept the option for "manual" 
operation of the EAS.  Because the FCC rules still allow  manual operation 
even for an EAN, any FCC defintion of "immediate" must be considered in a 
human time-scale, not just a computer time-scales.  Humans do not react 
in micro-seconds. It takes humans seconds to minutes to react.

Since all EAS equipment must have a minimum of two minute streaming audio 
buffer, let me argue:

Immediate means the complete EAN message must be re-broadcast "live" from 
the beginning to the end; and any buffering or delays (operator or 
automation) must not to exceed the two minute audio buffer (or less) 
required in the FCC rules.  No you can't just make your audio buffer 
bigger, and get a longer delay (intentional South Park reference).

Other transmission media delays such digital encoding delays, switching 
delays, etc. didn't exist in 1994.  So I would argue as long as they are 
"inherent" in the transmission media.  As long as they are not different 
for a "live" national transmission, i.e. no tape-delay for the West 
Coast, digital transmission encoding delays aren't included just 
like the satellite hop delay.

As always, the FCC disagrees there is any ambiguity with its rules, and 
declines to clarify or answer questions about them.