[EAS] Attention signal on an RMT

[Sean Donelan]

On Thu, 30 Mar 2017, Adrienne Abbott wrote:
> How much of this confusion comes from the rules for Low Power stations 
> which are not required to install full EAS equipment and as a result 
> can't generate the header tones and attention signal. These stations are 
> supposed to break programming and read the script for the test. How many 
> of you have had a Low Power station ask for a copy of the RMT script? 
> How many Low Power stations in your state have read the RMT script for 
> the test that was issued at 2:20 AM?

The EAS decoder-only rules are poorly written, and don't match the 
technical reality. Since the purpose of the required monthly test is 
ensuring a Presidential audio message can be relayed, it does not make 
technical sense for an announcer to read the RMT script at a low-powered 
station instead of the EAS decoder-only unit relaying the audio. In an 
actually National Activation, how would the announcer at a low-powered 
station get a copy of the presidential message to read on the air?

All the EAS decoder-only units sold receiver and forward EAS messages 
exactly like EAS encoder/decoder units, including required monthly tests. 
The only thing decoder-only units don't do is locally *Originate* alert 
messages.

However, I wouldn't eliminate the EAS decoder-only rules.

Instead, I would eliminate the EAS encoder rules.  EAS participants 
shouldn't be reasonable for *originating* EAS alerts.  EAS encoders should 
be controlled by, and EAS alerts should be originated by, official 
sources.  EAS participants (radio, tv, cable, IPTV, etc) should only need 
EAS/CAP decoders, not encoders.  Most of the complexity in the rules are 
due to the requirements for origination, intermediate daisy chain
distribution, and patchwork exceptions for different types of licensees 
(i.e. DTV, cable, TV, etc).  The EAS/CAP decoder-only rules are relatively 
simple when you remove the other stuff.

I understand the political and technical realities which make that 
unlikely.  The FCC can't require state and local governments to 
participate in the EAS. Which means the national EAS would break if a 
state or local government didn't participate. So, the EAS rules are 
written to depend only on FCC regulated entities, which means EAS 
encoders/decoders for almost everyone.