[EAS] Answering the right question - EAS Handbook

Sean Donelan sean at donelan.com
Tue Aug 1 14:16:24 CDT 2017


On Tue, 1 Aug 2017, Dave Kline wrote:
>>> Right off the top "guidelines which MUST be followed by..."
>
>> Does not require a physical copy of the state EAS plan at every operator's duty station.  EAS Participants can write their own SOPs based on the state guidelines.
> I agree but try telling that to the mock inspector.

Only real FCC inspections matter.  Mock inspectors are mock. I've looked 
at a lot of real FCC NOV/NAL, and I couldn't find official violation which 
listed "not having a physical copy of the state EAS plan."  Several 
listed a missing the FCC EAS Handbook, or failure to monitor the correct EAS source listed 
in the state EAS plan, but never missing a copy of the state EAS plan. 
Usually the FCC violation starts with "EAS not functioning, and no 
EAS records kept," and then adds more stuff.  I'm not a communications 
lawyer, not legal advice.

>
>> Does require a physical copy of the useless EAS Handbook at every operator's duty station. Not allowed to modify the text of the EAS Handbook beyond filling in the blanks, even when inappropriate for a particular facility.
> Yeah! Well they don't let you modify the wording on a 1040 just to make your tax bill the way you want it either.
> What's ya expect?
>
> I almost completely re-wrote last years plan to fit with station operations.
> Then I found out that even though the document was editable, you weren't supposed to edit it.
> I posted two copies... The edited version called "Unofficial Operator's Copy". And another one called "Show this to the Inspector."

The IRS does not prohibit bookstores from selling manuals "How to do your 
own taxes." CPA's can provide clients a summary of their tax information 
in different formats, along with the tax form for signature by the 
client.  The IRS cares about the tax form you submit to the government, 
not any extra forms an auditor keeps in the office or prepares for the 
client (as long as the numbers aren't different in a separate set of 
ledgers).  You must to keep tax records, but the IRS doesn't specify how, 
even if you keep them in a shoebox.  Your tax audit may be very painful 
when you dump a shoebox on the IRS auditor's desk, but those are still 
tax records as far as the IRS is concerned.  Again, I'm not a tax lawyer, 
not tax advice.

Put the official EAS Handbook in a sealed plastic envelope, and show it to 
the FCC field agent when asked.  Otherwise its a useless document.



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