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Re: Satellite station status
To: "CRTech" <crtech@crtech.org>
Subject: Re: Satellite station status
From: Jim Turvaville <jim@rt66.media>
Date: Fri, 05 Oct 2018 08:34:56 -0700
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Stations which are all simulcast as yours are can be compliant with EAS having a single box at the main station without the license designation of "satellite" as was previously the case.  As long as they operate as satellite stations, whether they are technically licensed that way or not, they will be compliant. 

The use of a single EAS system for the facilities is in compliance with Title 47 CFR Section 11.11 which states:

 "Analog and digital 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 percent 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."

This is further clarified by the underlying FCC Report and Order FCC 02-64 (Paragraph 67) for this section states:

 "67. We will amend the Part 11 rules to exempt satellite/repeater stations which rebroadcast 100% of the programming of their hub station from the requirement to install EAS equipment.  Specifically, we will consider the use of a single set of EAS equipment at a hub station (or common studio/control point where there is no hub station) to satisfy the EAS obligations of the satellite/repeater stations which rebroadcast 100% of the hub station’s programming.  This exemption will apply to existing satellite/repeater stations and any proposed new satellite/repeater stations.  As the Public Broadcasters point out, the satellite/repeater stations will comply with the requirement to transmit all national EAS alerts because all national alerts will be passed through from the hub station.  In addition, we acknowledge that it may be unnecessarily burdensome for the governmental and educational institutions operating these satellite/repeater stations to incur the substantial cost of installing EAS equipment at each such satellite/repeater station for the sole purpose of being able to transmit state and local EAS alerts, which are voluntary under our rules.  Furthermore, only a small number of broadcast stations will be eligible for this exemption.  We emphasize, however, that if any of the satellite/repeater stations start originating any of their own programming, they will be required to install EAS equipment.  Finally, we note that some models of EAS equipment have the capability to monitor the assigned EAS sources for more than one local EAS area, i.e., a hub station may have the capability to monitor the assigned EAS sources of some or all of its satellite stations in addition to its own sources.  Where this capability exists, we strongly encourage the hub station to voluntarily transmit at least the most serious local emergency alerts (e.g., tornado warnings) over its entire network of satellite stations to help ensure widespread dissemination of vital emergency information to the affected community or communities."

Jim "Turbo" Turvaville -  SBE Certified Radio Engineer 
Turbo Technical Services -  www.jimturbo.com 
Route 66 Media - www.rt66.media

---- On Fri, 05 Oct 2018 08:08:30 -0700 Jim McDermott <jim@spiritfm.org> wrote ----

Here's a question for the collective:  We used to send in an informal letter requesting a main studio waiver for our network stations and part of that letter asked for the station to be designated as a "satellite" of our flagship station, KCVO-FM. With the demise of the main studio rule and no need to apply for a waiver, how do we get that "satellite" designation on our license so we don't have to have EAS equipment at the remote stations? Anyone dealt with this yet? We bought a commercial station in June, and applied to make it non-commercial, but there is no place on the 302 form to ask to be a satellite station.

Jim McDermott
President, Lake Area Educ Broadcasting
Spirit FM Radio & The Pulse Channel
Lake of the Ozarks, MO

Follow-Ups: Re: Satellite station status
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