[EAS] Form-Two Deadline - No Time Zones Stated!

[Dave Kline]

I have seen about three separate instances now where the deadline for ETRS Form-Two has been (I believe erroneously) listed to be Midnight on August 12, 2021 "Eastern Time." (This assumes the test occurs on August 11th.)
While it is correct that the FCC has essentially given us an extra day to file Form-Two, Section II of the notice showing this year's deadlines for forms submissions, does NOT reference any time zone when listing those deadlines.

There were two parts in the request made to the FCC regarding ETRS form deadlines. The first being to grant an extra day to submit Form-Two. The second request was to eliminate any reference to time zones when stating those deadlines. Without any reference to a specific time zone, (as was done in the past) my interpretation is that the deadlines shown will be local times for the stations being reported.

Here is the text from the FCC notice, DA 21-680 Released: June 11, 2021. 
II. EAS TEST REPORTING SYSTEM AND RELATED DEADLINES
The ETRS is available to accept filings in connection with the 2021 nationwide test. Pursuant to Section 11.61 of the Commission's rules, EAS Participants must renew their identifying information required by ETRS Form One on a yearly basis.18 Accordingly, all EAS Participants must complete the 2021 ETRS Form One on or before July 6, 2021. On_or_before_August_12,_2021,_EAS_Participants_must_file_"day_of_test"_information_sought_by_ETRS_Form_Two.19On or before September 27, 2021, EAS Participants must file the detailed post-test data sought by ETRS Form Three.20 ETRS Forms Two and Three will become available in the ETRS at the time of initiation of the 2021 nationwide test.
The wording is a bit confusing. It was written this way to satisfy some legal requirements. "On" or before August 12, means you can submit on the 11th (recommended if you only manage one or two EAS units) or "On" the 12th. Which means before midnight "On" the 12th. If you don't get the form submitted in time to be home for dinner on the day of the test, do it the next morning over coffee. Hopefully this will help prevent server "pile-ups" like we've seen in the past.

Past notices conflicted with FCC regulations. 11.61 does not list time zones for ETRS deadlines. They have never been a thing other than in the notices preceding the tests. 11.61 states that you have 24 hours "after the test" to submit Form-Two. It also says that these deadlines are at the discretion of the FCC. Now the only reference to Eastern Time is to note when the test will takes place.

Stations in the Eastern time zone had the least amount of time to submit the "day of the test" information. You had a bit more in other time zones. But pretty much everyone had less than a day. This year the FCC granted 24 hours plus, regardless of where you are. The request to remove any reference to time zones for deadlines was to avoid confusion about the exact time when the forms are due. The playing field has been leveled.

And to prevent any confusion for next year due to assumptions carried over from previous years, as of right now the 24-hour extension is only for the 2021 NPT. That extension may be continued in the future, but don't automatically assume that will be the case.

I advise everyone to read the entire notice for yourself and make up your own mind.

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Dave Kline - Solder Jockey
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