[EAS] Proposed Error Reporting

[Sean Donelan]

On Fri, 13 Jul 2018, Adrienne Abbott wrote:
> Are they officially phasing out the CAP converters? I just did a quick
> read-through of the Notice and in the Compliance Timeline, it looks like the
> equipment requirements eliminate the use of CAP converters.

That was part of my late comment (which I guess in legal latin is 
an ex-parte filing) on July 3.

I don't think its official, but that's the result.

Implicitly, the way the Commission wrote the compliance paragraph it 
effectively will make legacy (End of Life) EAS decoders with CAP 
converters non-compliant. A footnote asserted that 93.2% of EAS 
Participants use modern EAS decoders or encoder/decoders, which all have 
integrated CAP functionality.

I don't know if it makes a practical difference in the real world. Its 
likely not worth the effort to find the last 1,000 EAS participants with 
end of life EAS equipment. That equipment is at least 10 years old, and 
barely compliant now. They could ask for a waiver, or continue to lay-low 
and hope the Commission never notices.

Not a lawyer, as always if you want a legal opinion pay your own legal 
advisor.