[EAS] NWS Status as an EAS Monitoring Source

[Sean Donelan]

On Sun, 22 Aug 2021, tpt at sevenrangesradio.com wrote:
 Here's the point of this discussion. Several years ago I remember 
 reading about the FCC issuing an NOV to a Wyoming station because they 
 were not monitoring the assigned stations under their state plan.  The 
 WV state plan, and I suspect a number of others, simply lists an NWS station 
 and maybe a choice of two state relays.

A little regulation archeology.  The FCC used to publish an EAS mapbook, 
using the information from state EAS plans. The FCC Mapbook listed ONLY 
the mandatory, assigned EAS monitoring sources.  It did not list any 
optional sources such as the NWS, state/local VHF/UHF networks, etc. 
in state EAS plans. So there was no confusion between mandatory assigned 
EAS sources and optional EAS sources.

The FCC stop publishing the mapbook around 2000.

If you read all 50 state EAS plans, there is a lot of variability. A few
states are very good.  A few states are very bad. Most states are ok.
Some state EAS plans carefully distinguish between mandatory national EAS 
sources, recommended state/local EAS sources and supplemental EAS sources. 
Other state EAS plans don't.

 Under the WV plan that's an AM 
 and an FM for most stations. My Wheeling FM relay is 51 miles from my 
 one studio--on the day of the test there was a thunderstorm between the 
 two of us, and very poor reception.  The alternative--WWVA, is usually 
 marginal on a good day, and gone at night.

The FCC wrote the Part 11 rules so contacting the FCC is always the 
very last resort.

SECCs have the authority to adjust almost all local EAS monitoring 
assignments within their state EAS plans themselves (with a few caveats, 
and FCC monitoring prorities). If the required EAS sources in the 
state EAS plan cannot be received, you should contact the SECC to request 
alternate arrangements (i.e. assigned a different EAS source, different 
EAS local area, different EAS reception methods).

Although only a dozen EAS local areas (out of 450 EAS local areas) cross 
state borders, there is nothing preventing SECCs coordinating in
different states.

SECCs in different states can agree to assign stations to EAS monitoring 
sources in adjacent states. Although the rule says "assigned," in practice 
the stations tell the SECCs what they can receive. Just be careful to 
prevent national level EAN message islands in the daisy-chain and 
single-point of failures.

As long as the alternate arranagement is on file with the SECC (and the 
SECC didn't ignore the FCC monitoring prorities when adjusting the state 
EAS plan), it should be acceptable for Part 11 purposes.  Its all about 
the paperwork.

The new FCC Alert Reporting System has separate pages for listing 
alternative national-level monitoring sources and state/local monitoring 
sources for individual EAS participants. NOAA weather radio is listed as 
"optional," not as a monitoring assignment, on both pages.

The part 11 rules imply, only if no alternate arrangements are possible, 
then contact the Chief of the PSHSB for a waiver (as a last resort).

I don't know for certain how many stations obtain EAS monitoring 
source waivers from PSHSB, but my impression is very few. Most problems 
are resolved through the SECCs using alternate arrangements.

An alternate arrangement is not something you do alone.  It still needs to 
be coordinated through the SECC (or if the SECC is not functional in your 
state, through PSHSB).

As always consult a licensed attorney with experience in communications 
law.