[EAS] FCC R&O

[Dave Turnmire]

A few initial comments/questions regarding this R&O:

 1. Currently, all EAS Participants have (or should have) a copy of the
    State Plan.  Some states have chosen to not to post it on public
    websites for security reasons...a choice the FCC of late has done an
    end-run around.  But with this R&O, the FCC seems to be worried
    about security issues all of a sudden.  But it isn't clear to me who
    will have access to the State Plan at the local/state level other
    than certain members of the SECC involved.

    Will EAS Participants have access to the entire plan? Presumably
    they'll at least have access to their own monitoring assignments. 
    And it seems clear that the general public won't have access to the
    state plan (not via ARS at least).  But that allows for a lot of
    mystery in between.  It would seem to me that in general, the State
    Plan should be widely available.  But for security reasons some
    parts are probably best not made so easy to get.  Such as NP, SP,
    and LP monitoring assignments.  Others may have other ideas.
 2. It appears this is going to be integrated somehow with ETRS. 
    Details unclear.  IMHO, having it automatically populate the ETRS
    monitoring assignments and operational area names is a good idea.  I
    think the first week of Databases 101 they taught me not to do what
    ETRS (and TVSTudy) does about letting every Tom-Dick-And-Harry make
    up their own names and data and then encourage others to use that
    same potentially bad data in their filings!  [How could that
    possibly go wrong?]
 3. On the other hand, the FCC has a track record of giving "all or
    nothing" privileges to their system.  Example... the same user
    credentials that allow a staffer to post EAS National Test data
    allows them to file changes to station licenses.  So much for
    "compartmentalization" as a basic security concept. I would hope...
    that the ARS will do better in this regard. Including the potential
    for "read-only" access.
 4. Given the apparent access restrictions to the State Plan... I would
    hope that ARS will provide for downloading a PDF version of the plan
    (both draft and submitted).  After all, we need to get copies of
    this to others for various reasons (including the SECC's own
    internal approval process).  The R&O claim the ARS will be a long
    term time saver for the SECCs.  Quite possibly true... IF... we
    don't have to type everything twice...

    It would probably be best if the monitoring assignments be a
    separate download... perhaps available in both PDF and XLSX format. 
    For that matter, it might be handy for ARS to allow importing of an
    XLSX file with monitoring assignments.  Many of us likely already
    have such a file and it may (or may not) be relatively easy to
    modify its format to match ARS's needs and save us some data entry time.

Your thoughts?

Dave

On 4/11/2018 12:21 PM, Barry Mishkind wrote:
> The FCC has released a Report and Order on Part 11 changes.
>
> There are a lot of pages, but it looks like the main thrust is change
> the procedure for State Plans and a new requirement to upload
> them to the FCC and update them.
>
...