[EAS] so what do we know about the NPT?

[Sean Donelan]

On Mon, 16 Aug 2021, Rod Zeigler wrote:
 The FCC finally acted on a years old request by Sirius or XM (prior to their 
 merger) to allow them to NOT send EAS tests. The FCC agreed with them last 
 year and they quit sending RWT's.
 Getting the FCC to reverse that ruling might be a bit difficult now.

As I suggested in my filed comments to the FCC, which the FCC ignored....

Multichannel satellite services should perform "full" weekly and monthly 
tests on at least one consistent, free-to-receive main barker channel 
monitored by other EAS participants.

I also supported weekly/monthly tests on a rotating subset (e.g. 10%) of 
subscription program channels of multi-channel services. The rotation 
would cover all subscription program channels over the course of a year.

And finally, I suggested making the 47CFR 11.61 testing rules more 
consistent for all services. The current rules are a mess of exceptions 
added over the decades.  Multichannel digital cable, IPTV, DBS all have 
the same business concerns as SDARS (SiriusXM).

Maybe to get NAB and NCTA to agree on something, digital operators which 
choose rotating EAS tests on a subset of program channels must also exempt 
local stations from EAS overrides.  If an digital operator with equipment 
capable of rotating EAS tests on program channels, should also have the 
capability to exempt certain channels from EAS overrides.