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

[Gary Timm]

Sean,
Regarding your thoughts on the EAS Handbook, CSRIC actually had many of the same thoughts you did.

We felt we had to follow our FCC mission to revise the EAS Operating Handbook, so we did that, and made it strictly for the operator on duty - in the rare cases that occurs.  But that is the FCC's designed mission for the Handbook.

But we also felt, as you do, that the person responsible for EAS operations (Chief Operator, etc.) needed additional specific guidance.  So in the Appendix B Instructions for filling out the Handbook, we included info for the Chief Operator, such as guidance for LPFMs, and FCC actually moved some of that guidance into the Handbook.  And we went above and beyond that by creating Appendix C - Suggested Content of an EAS Participant Guidebook - again feeling, as you do, that the person responsible for EAS needs this further guidance.

But we felt this additional guidance does not belong in the Handbook, which is for the kid-in-the-chair in the studio.  Addition guidance would confuse, not help, the kid-in-the-chair.  So we suggested the FCC create an EAS Participant Guidebook for this purpose.  If FCC does not pursue that idea, perhaps the SBE EAS Education Committee can tackle it.

CSRIC went one step further and created Appendix D - EAS Rules Identified as Needing Update.  As you say, many times this additional content in committee reports gets lost, so I've been riding the FCC to address those items, bringing up to them anytime one comes to light - such as the 8-25 second Attention Signal rule that needs to be updated that was recently discussed here on the list.

So CSRIC did agree with you that the Chief Operator needs additional EAS guidance, but we didn't agree that it belongs in the EAS Handbook.

Thanx for your comments,
Gary Timm, Chair of 2016 CSRIC V EAS Operating Handbook Update Subcommittee

From: Sean Donelan <sean at donelan.com>

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.

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