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Re: No local studio requirement?
To: CRTech <crtech@crtech.org>
Subject: Re: No local studio requirement?
From: Alan Kilgore <wrvm.engineer@gmail.com>
Date: Thu, 5 Apr 2018 14:09:31 -0500
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References: <B8DB6841-90DF-4098-B594-775D0785FA8E@kbjs.org> <AB51A9A9EC341A479655F592221FE8BD77247B7B@mbx028-e1-va-4.exch028.domain.local>
Yes, you can control the station remotely, but there are limitations and some resulting confusion. I am certainly not an attorney! But, let's be careful not to overlook something important by hastily grouping too many issues into the same basket. Sometimes when we hear an answer to a question we forget some specified detail that dramatically changes the answer for other conditions.

Look up 47C.F.R. 11.21 & 11.52 and then the EAS State Plan for where the station is located. Also see the FCC's Self-Inspection Checklist. For FM stations it is Question 68: "Is the EAS decoder/monitor tuned to receive EAS activations from the monitoring priorities named in the State EAS plan?"   (See page 20 at https://www.fcc.gov/general/broadcast-self-inspection-checklists)

Most (but not all) main studio waivers of the past requested both a waiver of main studio waiver and a condition of the request was to operate as a satellite of another station (100% simulcast of another station, sometime called a "repeater station"), re-transmitting the programming of a commonly owned flagship station. It would operate from the main studio of the flagship station and that station's EAS also qualified for EAS compliance for all satellite stations re-transmitting that signal without further requirement for EAS waivers.

Some (fewer) stations that requested main studio waivers in the past requested to originate programming from a remote location which may or may not be at some other station's location but nevertheless did *not* simulcast programming of another station. Such stations did not automatically get EAS privileges of another station's location because they were not re-transmitting a signal already containing EAS content. To follow EAS rules by FCC and state plan, they had to either find a technical way to comply with the request or seek an exception (waiver) for what EAS stations to monitor.

The FCC rules require stations to monitor the stations specified by the state plan which are based upon where the transmitter is located within the state. The state EAS authority can grant a waiver for a plan-specified alternative station or a waiver to allow a totally different substitute for the required station(s) to be monitored. In practice, you keep a copy of such waivers in the FCC Inspection File for the station in case that is ever challenged or in case of FCC station inspection.

With the most recent main studio rule deletion, I can't say how differently the FCC expects to interpret the EAS rules, which did *not* change as far as I can tell. I also do not see any update to the EAS questions in the FCC's Self-Inspection Checklist.

Yeah, "the devil is in the details"... but we have an eternal Redeemer.


On Thu, Apr 5, 2018 at 10:13 AM, Jack Epperson <Jack.Epperson@alphamediausa.com> wrote:
Where the EAS is located physically does not matter as long as you are monitoring the location of your control point. Thus if you are in Miami and sending that content to Seattle, then the Seattle listeners will be hearing the local Miami hurricane watches, warnings etc. on that frequency in Seattle.
Now good broadcasters that desire to serve the local listeners will use the actual local are EAS coverage, but that is not what the rules require. BTDT with the attorneys.

Jack Epperson
Chief Engineer
Alpha Media- Aurora, IL
Matrix Broadcasting- Crystal Lake, IL
WERV, WFXF, WZSR
SBE  CBRE  CBNT, GROL


-----Original Message-----
From: JohnPaul [mailto:johnpaul@kbjs.org]
Sent: Thursday, April 05, 2018 10:03 AM
To: CRTech <crtech@crtech.org>
Subject: [CRTech] No local studio requirement?

I’m just curious as to how other broadcasters feel the FCC’s recent abolishment of the local studio requirement will or could affect your local operation? Also, how does EAS fit into this ruling.  Where would the EAS box be located if there is no local studio?

John Paul Little

Sent from my iPhone
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--
____________________________________
Alan Kilgore, CPBE
WRVM Chief Engineer
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