[EAS] FCC R&O

[tpt at sevenrangesradio.com]

Replying to Dave's comments:

"1. Currently, all EAS Participants have (or should have) a copy of the
   State Plan."
 
I can't find a CFR section that require this (maybe it isn't in Part 11) but there needs to be somewhere for station personnel (engineers, ops.mgrs., etc.) to get at least operational details (monitoring assignments, for example) as well as the ability to see if the state plan has the current information on their stations.

"2. It appears this is going to be integrated somehow with ETRS. 
   Details unclear. "

As Dave noted, the ETRS allowed the first filers to define operational areas, and such, leading to confusion as everyone else entered in their info. Also ETRS didn't allow the listing of relay sources outside AM/FM stations. In WV, a number of stations used the WV Metro News sat feed as a source (including our local relay station).
 
"3. On the other hand, the FCC has a track record of giving "all or
   nothing" privileges to their system."
 
One of the many things I didn't like about ETRS--the e-mail/password used for ETRS allowed access to dozens of other areas. The system they used was clearly designed for attorneys and consulting engineers with a number of different clients. That's fine,--and the stations I filed the EAS test reports for were also my clients (I do a pro-bono legal for a number of low powers and non-coms)--but not a good system where those accessing the system would normally not need or should be allowed such wide access.
 
However, not the case here. It seems from the screen shots in the Report and Order, the State Emergency Committees--or whoever is filing the state plan--would be getting their own password/log-in combination that would be particular to this system.
 
"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). "
 
Someone is going to have to play with their system to see how it actually works.  Looks to me like there are a number of "fill in blanks" boxes which are not conducive to a very readable plan. Unless the system allows uploading of PDF exhibits. Hard to tell from the screen shots in the Report and Order.
 
One way around the security over-kill is to have a public plan available for download from the state source. That way the info needed by the stations is easily available. I also wonder how the various state open records acts would come to play here.