[EAS] Sage Update Extended

[Sean Donelan]

On Wed, 6 Nov 2019, Mike McCarthy wrote:
> Looks like the FCC has heard from radio people about the compressed time
> line and has acquiesced to delay their conformance deadline to 1/20/2020
>
> Read: https://docs.fcc.gov/public/attachments/DA-19-1144A1.pdf

The FCC PSHSB guidance doesn't extend the conformance deadline.

The PSHSB guidance merely pointed out the existing Part 11.35 rules allow 
a licensee to continue to operate up to 60 days with defective (partilly 
operational, non-operational, non-conformant, etc.) EAS equipment.  This 
is always true whether the EAS box is struck by lightning, stolen, 
internet outage, software bugs, or an expiring CAP certificate.

If you fail to update a Sage box to Rev95, or fail to install new 
certificate bundle in a DASDEC box, those boxes *WILL NOT* validate 
CAP messages issued through IPAWS after November 8, 2019 at 1:20pm EST 
(1820 UTC) in compliance with FCC Part 11 rules.

What the boxes do with unvalidated CAP messages depends on their 
configuration. In any case, and any configuration, the boxes will not be 
compliant with FCC rules without an update (Sage) or new certificate 
bundle (DAS) before November 8.

Trilithic and Gorman-Redlich handle CAP certificates differently.
Customers of those manufacturers should check with the manufacturer if 
their EAS equipment will still be compliant. My guess is G-R and Trilithic 
will continue to validate CAP messages after November 8, but I'm not the 
manufacturer.

As the existing rules already state, if the EAS equipment is still not 
fully operational (e.g. fully compliant with CAP validation) after 60 
days, a licensee must file an informal request for additional time to 
continue to operate while repairing EAS equipment.

The only effective change in the PSHSB guidance, the informal request to 
operate EAS equipment with defective CAP message validation (only) must 
be submitted to the special FCC email mailbox (alerting at fcc) instead 
of the local FCC regional field office.

All the other Part 11 EAS rules remain enforce, including the rules 
about licensees maintaining EAS logs.  While your EAS box is not fully 
operational (i.e., CAP message validation), you still must document in 
your EAS logs when it started (November 8), what steps you have taken to 
repair it, and missing required EAS tests.

There is a weird Part 11 rule, the monthly test script must still be 
announced on-air, even if the EAS box is non-functional. Everyone misses 
that one.

INAL, as always consult with your licensed communications attorney for 
legal advice.  Consult with your equipment manufacturer for technical 
assistance with your EAS equipment.