Is Your EAS Gear Ready for Action?
[April 2014] The Spring NAB Show had more than the usual EAS activity this year, at least four sessions focused on status, problems, and solutions.
The big takeaway: it is always a good time to check your EAS receiver and local practices to ensure everything is working correctly, but a lot of work remains to get more cooperation between broadcasters and emergency managers.
Unfortunately there are a lot of people who still have not grasped the fact that the FCC really wants their EAS rules followed.
Top Concerns
Check out what fines are among the most common the FCC has been issuing and you will quickly learn that the Public File and EAS are the two “lightning rods” for FCC enforcement.
The FCC has once again underscored their authority in the area of the EAS with a record-setting $1.9 Mega-buck fine, issued to three companies for using EAS Tones in an advertisement for the movie “Olympus Has Fallen.” The EB hoped, as the old expression goes: perhaps that will get their attention.
However, apparently not all parties were paying attention. Within days after the announcement of that large fine, a spot for a barbecue charcoal company was to be released shortly, with – yep, you guessed it – EAS tones embedded. This time, though, I think this one got pulled rather quickly. At least there is no evidence so far that it got on the air anywhere.
Just a Few Months Late?
Yet another station (no names or call letters will be used) was cited recently for not having the equipment and/or updates needed installed to receive the IPAWS CAP messages from the FEMA.
As most are aware, the deadline for compliance with this requirement passed close to two years ago, now. Still, information I have is that there are plenty more of these still out there – and the FCC is starting to look more diligently for them.
Similarly, I recently heard from a station which had not been receiving the Required Weekly Test (RWT) for an extended period of time from a station they are assigned to monitor.
There are a couple of lessons I hope to impart here. But, do be cautious and understand: I am not a representative of the FCC nor am I an attorney. Any advice given here should be verified.
Checks on the Receiving Side
- Everyone is assigned two stations to monitor by the SECC; you must monitor those stations (although you can monitor more if you wish).
- If a monitoring assignment cannot be heard, you cannot change the sources on your own. This requires SECC approval (yes, the FCC gives the SECC that authority).
- Your station log must to show the reception of an RWT from both of those sources each week, unless the week contains a Required Monthly Test (RMT) or an actual use of the EAS, as was the case with the Oso mud slide recently here in Washington.
- If you have logged the RMT and two RWTs for the other weeks, plus any EAS activations, you are in compliance and can relax.
When Receptions are Missing
- If you fail to receive two RWTs, you must log that fact – and also log why you did not receive one or more of the tests.
- Generally when a test is not received, the proper procedure would be to contact other stations that are monitoring the same source to find out if they are receiving the tests. (This information is contained in your State EAS Plan for your Operation Area.)
- If you find that other stations are not receiving these tests as well, it is time to contact the source to see if they have indeed sent the tests. However, you have to actually make the effort to find out why they are not sending the tests. Just sending an email to that source and not receiving a response is not going to get you off the hook. That means following up by making a phone call.
- Do remember: you must log the results of your research providing the reasons why you are not receiving the RWTs.
Checks on the Transmitting Side
- Each week, your station must transmit an RWT (at random times in accordance with the FCC Rules).
- Any “real” use of the EAS for any weather or emergency issue meets the requirements.
- If you find that your station has not been transmitting these tests, you need to find out why and log the results of that investigation.
Some Recommendations
As you work through the checks above, you may find that everything is working. If so – that is great. If not, here are some thoughts on how to make sure everything meets FCC specs.
- All stations should check the operation of their EAS equipment weekly at the least to avoid having a problem repeat. Personally, I check those units for which I am responsible no later than each Tuesday.
- If your station sends RWTs manually and you find you have an operator or personnel problem causing an FCC EAS rule compliance issue, seriously consider having your EAS Encoder perform the RWT task for you automatically. You will likely annoy someone on your staff, however that sure beats having the FCC issue an NOV – or perhaps an NAL.
- Make sure the EAS Handbook is available at the station’s Control Point.
- If you have any questions about EAS and what is legal and what is not:
- Check the FCC’s EAS Rules (They are in Part 11, and pretty easy to understand).
- Get an opinion from your station’s legal department or FCC Attorney.
- Post your questions on the EAS Remailer, and check out the EAS Forum.
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Clay Freinwald, a frequent contributor to the BDR, is a Seattle market veteran engineer, who continues to serve clients from standalone stations to multi-station sites. You can contact Clay at K7CR@blarg.net
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