[sbe-eas] Required things to relay [was Chilling Effect]

[Darryl Parker]

Adrienne,

The applicable section of Part 11 is 11.11(b):

"(b) Class D non-commercial educational FM stations as defined in § 73.506, LPFM stations as defined in §§ 73.811 and 73.853, and LPTV stations as defined in § 74.701(f) are not required to comply with § 11.32. LPTV stations that operate as television broadcast translator stations, as defined in § 74.701(b) of this chapter, are not required to comply with the requirements of this part. FM broadcast booster stations as defined in § 74.1201(f) of this chapter and FM translator stations as defined in § 74.1201(a) of this chapter which entirely rebroadcast the programming of other local FM broadcast stations are not required to comply with the requirements of this part... Broadcast stations that operate as satellites or repeaters of a hub station (or common studio or control point if there is no hub station) and rebroadcast 100% of the programming of the hub station (or common studio or control point) may satisfy the requirements of this part through the use of a single set of EAS equipment at the hub station (or common studio or control point) which complies with §§ 11.32 and 11.33."

The key test is whether the repeater station carries 100% of the programming of the hub station. If the repeater station breaks for local inserts of any kind, then the stipulation does not apply, and EAS equipment is required.

Regards,
Darryl


________________________________
From: sbe-eas-bounces at sbe.org [mailto:sbe-eas-bounces at sbe.org] On Behalf Of Adrienne Abbott
Sent: Thursday, February 18, 2010 5:40 PM
To: 'SBE EAS Exchange - a mail list for discussion about the EmergencyAlert System and other emergency communication issues.'
Subject: Re: [sbe-eas] Required things to relay [was Chilling Effect]

Frank—
This brings up a discussion I recently had with one of our engineers…I have several cases where a broadcast company has main studio waivers for several full-power stations that are licensed to very rural communities but carry the same programming as one of the company’s metropolitan stations. That programming includes EAS tests activations received and sent by the “mothership”. The rural stations do not have their own EAS equipment because, among other reasons, there’s no one to check the printouts and do a weekly log. However, I don’t think a Main Studio Waiver includes an exemption for EAS and monitoring assignments and some of these rural stations are in areas separate from the “mothership” Operational Area. And the tests and activations carried by these rural stations from the “mothership” don’t really apply to the communities of license, even if the “mothership” includes the counties in their list of Locator Codes. . In some cases, these remote stations are in other states, including states that are in a different time zone than the “mothership”. Is this legal? The manager of one of these companies does not carry any local EAS activations because they don’t apply to all the stations in his network. Is this just a loophole in Part 11? How are these stations going to handle the upcoming National tests?
Adrienne

“Radio burps, it cries, it needs to be fed all the time, it requires constant attention, but we love it.” Jim Aaron WGLN
________________________________
From: sbe-eas-bounces at sbe.org [mailto:sbe-eas-bounces at sbe.org] On Behalf Of felucia at att.net
Sent: Thursday, February 18, 2010 9:42 AM
To: SBE EAS Exchange - a mail list for discussion about the EmergencyAlertSystem and other emergency communication issues.
Subject: Re: [sbe-eas] Required things to relay [was Chilling Effect]

Hi Clay,

For the RWT I meant as follows;

11.51
m) ...... When transmitting the required weekly test, EAS Participants shall use the event code RWT. The location codes are the state and county for the broadcast station city of license or system community or city. Other location codes may be included upon approval of station or system management. EAS messages may be transmitted automatically or manually.

Thanks
Frank


-------------- Original message from "k7cr" <k7cr at blarg.net>: --------------


Some comments on Franks post -

Clay Freinwald
Unless something has changed, the FCC rules usually concentrate on a station's city of licensee and providing a certain level of field strength over the city of license.

CF - Yes Frank, this is still the case.  However, in many cases, the City of License has little or nothing to do with the focus of the station.

Meaning a city of licensee determines what plan you are in.

CF - Sorry Frank - This is not always the case.  Case in point - A 'Rim-Shot' station is licensed to City A, but it's focus and primary coverage area is City B.   In planning Monitoring Assignment as well as which Local EAS Area the station is to work with, the COL is meaningless in many cases.    (I can provide a number of additional examples if desired)

Also the EAS rules say a station must use the FIPs county of license number in RWT tests.

CF - Not quite sure what you mean by this

Of course, TV and radio signals know no bounds and listeners in an adjacent state will get the alerts as well.

CF - Of course.

CF -  The bottom line is that the SECC should be the body that determines who monitors what and what areas the station participates with.
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