[EAS] Proposed Error Reporting

[Rod Zeigler]

To me it makes no sense at all in having FCC license holders themselves 
report "errors", no matter what the final definition of "errors" becomes.
License holders should only be responsible for forwarding alerts if they 
meet the criteria, not determining if they are in error.
Should a license holder ORIGINATE an alert in error, that could be 
reportable as a mea culpa on the part of the licensee, but this would be 
a very rare occurrence.
License holders in general should not, except under the most extreme of 
circumstances, be originating alerts.
The previous statement does not include those who routinely originate 
RMT's or other alerts (AMBER) as designated by their individual State Plans.
As much as it pains me to say this, initial error investigation and 
reporting would probably be a responsibility best left to SECC's when 
requested by the FCC.
The FCC created the SECC's and have been giving them more 
responsibilities as time has gone on, this could be just one more.
The initial error investigation should entail where the alert came from, 
when it occurred, and how it propagated.
The who, why, and other details should be undertaken by those with 
greater authority who would in turn report their results to those who 
can make a final determination and resolution.
I intend to submit the ideas expressed above as my response to the FNPRM.

-- 
R. V. Zeigler, Dir. of Eng.
Nebraska Rural Radio Assn.
KRVN-KTIC-KNEB-KAMI
Chairman, Ne. SECC
Exec. Dir. NEBA
www.krvn.com