[EAS] Answering the right question - EAS Handbook

[Dave Kline]

§ 11.21   State and Local Area plans and FCC Mapbook.

   EAS plans contain guidelines which must be followed by EAS
   Participants' personnel, emergency officials, and National Weather
   Service (NWS) personnel to activate the EAS.

Right off the top "guidelines which MUST be followed by..."

So while it may seem like having a state plan is implied, it's a pretty clear implication that there needs to be something in place.
"Guidelines" is somewhat vague in terms of optional or not, but "must" clarifies it. 

The "National Plan" or whatever you want to call this thing we just downloaded from the fed is not supposed to be all inclusive, down to the operator (DJ) level.
Or even at a state or local level. It seems it was all they could do to get this done, in spite apparently, of a lot of input to which they allegedly didn't listen. 
Do you really want the fed to be diving into more detail of how individual states, localities and stations operate?

I think the larger concern for what is implied is that these state plans are supposed to be approved by the FCC.
The last time we had an approved plan here was 2007, and I'm not certain that was ever really approved so much as just adopted as a default operating manual while awaiting some kind of official approval. Ten years later and we are operating on a hybrid plan that is a mix of the 2007 book and any changes made since then that appear on the state EM website. There is no one, all inclusive, set of instructions for how this state operates EAS, at least not that can be easily posted at an EAS operating point.

There is (or should be) a hierarchy:

National Plan - Very Broad Guidance, (one size fits all for what it's worth).

State Plan - More Refined, Takes it's cue from the National Plan and adjusts accordingly to the needs and capabilities of the state.

Local Plan if there is one - Even more Refined for a local area. FYI just as much implied as is the state plan. 
Still waiting for some kind of official blessing on that one as well.

Station Operating Instructions - For the DJ type person - The thing you refer to when you add the comment to the national Plan that says: "Per station EAS policy." 

I really don't see what's so hard about this that after 10 years we don't have something on a state level that's been anointed by some federal grand poobah. 

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Dave Kline
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On Aug 1, 2017, at 11:32 AM, Sean Donelan wrote:

>There is no published national EAS plan.

>State EAS plans do NOT contain specific operating instructions for a participant's EAS equipment. Interestingly enough, there is NO specific rule requiring EAS Participants have a copy of State or local EAS plans.
>Its implied by 47CFR11.21, but not stated.