[EAS] The 2017 EAS Handbook for LP-1's

[Sean Donelan]

On Sat, 29 Jul 2017, Gary Timm wrote:
> To those wishing for more detail in the new EAS Handbook, CSRIC had a 
> very though job in designing a Handbook with the flexibility to be used 
> by all EAS Participants, but we did the best we could.

CSRIC did an excellent job answering the wrong question.

I understand CSRIC was tasked by the FCC to answer particular questions. 
And the FCC created the questions for CSRIC. While the CSRIC members may 
feel personally invested in what they created, it shouldn't change that it 
wasn't the right question.

Who is the audience for the EAS Handbook?

Very few, and fewer all the time, EAS Participants have an 
operator-on-duty needing a handbook to perform EAS operations. In most 
cases, EAS Participants use equipment configured for automatic or 
semi-automatic operation. In today's world, the responsible person 
configuring the EAS equipment needs guidance, not the rare or non-existant 
operator-on-duty.

In the rare cases where an operator-on-duty still manually operates the 
EAS equipment, stations more likely prepare customized operation manuals 
based on the national and state plans with their individual equipment 
procedures. The person writing the station specific operations manual 
needs the guidance in the EAS Handbook.

Instead, the result of CSRIC answering the wrong question is an EAS 
Handbook devoid of almost all guidance needed by its actual audience.
The FCC EAS Handbook is a useless artifact that could be sealed in a 
plastic envelope and hung by the EAS equipment because the only person 
that will use it is the FCC field inspector.

CSRIC could have created a useful EAS Handbook containing guidance for 
people responsible for EAS at stations, and better using the expertise and 
historical knowledge of the CSRIC participants. But it created a document 
for the wrong audience and answered the wrong question.

This was the advice from industry in 2012 (5th R&O):

208. The majority of comments addressing this issue opposed elimination of 
the EAS Operating Handbook.  NCTA stated, "As a concise reference document 
for operators on the national EAS requirements, we believe that the 
handbook is still necessary and should be updated to reflect changes in 
Part 11 rather than eliminated or substituted with state plans." NCTA 
added, "The EAS handbook further serves as a reliable training and 
resource tool for EAS participants and covers areas that may not be 
included in the state plans." With respect to replacing the EAS 
Operating Handbook with State EAS Plans, NTA asserted, "state plans lack 
consistency, need updating, and some states have no plan on record." 
NAB expressed essentially the same views. AT&T opposed elimination of 
the EAS operating Handbook on grounds that it "provides much needed 
uniformity to the EAS system."

209. Monroe stated, "Regarding the EAS Operating Handbook, we do not feel 
it should be deleted, however it if is retained, the EAS Operating 
Handbook must be updated to correct a range of ambiguities, 
inconsistencies and errors." Trilithic stated that the EAS Operating 
Handbook should be "relegated to informational-only status." Trilithic 
also supported deletion of sections 11.54(a), (b)(2), and (5)-(8). 
Kenneth Evans (Evans) stated, "While I have used the FCC EAS Handbook to 
help train broadcast stationemployees, . . . I feel it might be more 
efficient to just provide a Quick Guide to cover the basic needed 
information." Evans added, "Such a sheet could provide the basic 
information in a concise form to provide an over all understanding of the 
rules from Part 11."

Instead the FCC tasked CSRIC as follows:

Updating the EAS Operating Handbook - According to section 11.15 of the 
Commission's rules, all EAS Participants must have a copy of the EAS 
Handbook located at normal duty positions or EAS equipment locations when 
an operator is required to be on duty and be immediately available to 
staff responsible for authenticating messages and initiating actions 
associated with the EAS process.  According to the rules, the EAS 
Operating Handbook states in summary form the actions to be taken by 
personnel at EAS Participant facilities upon receipt of an EAN, an EAT, 
tests, or State and Local Area alerts. It is issued by the FCC and 
contains instructions for the above situations.

The current handbook is obsolete and contains inaccurate instructions. 
The Working Group will analyze the manner in which the EAS should operate 
and each type of EAS Participant (e.g., broadcaster and cable service 
provider facilities) and shall make recommendations for textual and visual 
elements of a handbook suitable for each category of EAS Participant, with 
particular attention to be given to rural, smaller and less resourced EAS 
Participants.