[EAS] FCC Clarification on new EAS Handbook

[Sean Donelan]

On Tue, 13 Sep 2016, Gary Timm wrote:
> Regarding changes to the info in the EAS Handbook, and filling it out before posting it...
> The closest comparison I can think of is the IRS Form 1040.

There are many how-to books about doing your taxes, some tax books
include excerpts, clarifications and even corrections of IRS manuals
and publications.  The IRS doesn't prevent anyone from re-writing IRS 
manuals. Office supply stores are full of accounting ledgers and 
accounting forms.

The EAS Operating Handbook isn't a "form filed" with the FCC. The IRS 
specifies the format of forms filed with it for its processing purposes. 
But the IRS doesn't specify how you keep your own records; just that you 
have records. Over the years I've received all sorts of different types 
of "substitute" 1099's and w-2's from companies which were different from 
the IRS "official" forms.

> You fill in the portions that apply to you, you leave blank the 
> portions that don't, but you are not allowed to alter the form, and you 
> can't leave the form blank and consider your work done.
> It seems to me, the FCC is saying the same for the EAS Handbook - at 
> least for right now.
> I would think they have their hands full with ETRS right now, so I 
> wouldn't expect to see a new Handbook before the Nationwide EAS Test. 
> So I think they are saying, for now, go with our published Handbook, 
> errors and all.  They acknowledge that the Handbook needs to have 
> errors corrected and needs to be more customizable/user-friendly, and 
> they will address that in due time.
> So I think they mean, for now, use their published version, fill in the 
> blanks, and post it.
> That's my read on it anyway,

As a paperwork compliance exercise, and no other reason for the rule 
11.15, fill in the blanks in the official FCC handbook, print out copies 
for each normal duty or equipment location.

In the 1990's the handbook served a useful purpose as a holder for the FCC 
Red Envelope for authenticating EAS/EBS messages. Since the elimination 
of the Red Envelope, the handbook hasn't served much of a purpose, as 
evidenced by the errors in the handbooks, and being pretty much ignored 
other than the enforcement bureau dinging stations for not keeping a 
copy. Has any operator on duty used it for anything, other than to show 
an FCC agent in the last 20 years? Operators don't authenticate EAS 
messages anymore.

Nothing in 11.15 prohibits a facility from having separate operating 
procedures for your staff.  You can write your own instructions in any 
languages your staff understands, include any information relevant how 
your equipment works, or generally making a separate procedures manual
relevant for your operations.

If the FCC wants feedback on ETRS Form Three after the national test, 
people could suggest the FCC eliminate rule 11.15 because its obsolete and 
the FCC Operating Handbook isn't used.