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REC Statement: FCC Report on September, 2016 EAS Test

Submitted by on

I am disappointed but at the same time understanding of the recently announced statistics related to the participation of LPFM stations in the 2016 Emergency Alert System (EAS) test and the subsequent reporting using the EAS Test Reporting System (ETRS).  In the Commission's report, they claim that only 61 percent of LPFM stations participated in the testing.  Since LPFM stations can not operate as translators like LPTV stations can and they are not eligible for exemptions like satellite FM or TV stations, our percentage should have been higher as there was no significant reason why an LPFM station would be exempt from having operating EAS.

How we reached 1,620 LPFM stations
LPFM facilities from the 2013 filing window that were granted at least one license to cover application as of the date of the National EAS Test 878
Fully licensed LPFM facilities from the 2000~01 filing window series as of 4/20/2017. 741
Fully licensed LPFM facilities from the 2000~01 window series that had their licenses cancelled since the date of the National EAS Test 7
Subtract LPFM stations that, within the previous 6 months before the test, had filed STAs to go silent and had not filed a resumption of operations prior to the test date. -6
REC's calculation of the total number of operational LPFM facilities licensed at the time of the National EAS Test 1,620

I do feel that the Commission has overcounted the number of LPFM stations that were on the air and licensed at the time of the test.  Unlike the other services that were required to have EAS at the time of the test, LPFM was the only service that was actually growing in numbers as stations were coming on the air after the grants from the 2013 filing window.  The FCC claims there were 1,852 LPFM stations licensed, our count shows 1,620 licensed stations at the time of last year's test.   Even with that adjusted number, participation is still 69 percent, which to me is still a bad reflection on LPFM and gets me wondering what we need to do to increase compliance. 

Over the many years I have been working with LPFM, many stations and aspiring station operators have expressed serious concern regarding the high cost of EAS equipment.  For many stations, the EAS is as about expensive as the certified transmitter for the station.  This is the norm for a legacy product that is designed for legal requirement and is not mass-marketed like consumer electronics.  To make matters worse, there is the additional costs of lab testing and certification that is passed on in every unit.  

To make matters even worse, whenever the government makes a change to the EAS protocols, it will require a firmware change which may in some cases require additional costs to the end user of the EAS equipment.  The Commission has already demonstrated its unwillingness to work with viable software workrounds as demonstrated in last year's denial of a waiver requested by Gordon-Redlich to assure that their legacy equipment can still be used in the field.  

Section 11.34(e) of the FCC Rules allow for consideration for waiver of the costly certification process if the decoder was constructed for use by an EAS participant but is not offered for sale.  With that said, perhaps we need to look at the potential of developing an open source EAS, software that is distributed freely and uses existing commercially available parts to construct a computer system that properly monitors LP-1 and LP-2 stations, interfaces with IPAWS and interrupts the audio chain when appropriate.  If this can be done, it may be possible to achieve EAS compliance with an older junker computer or even something like a Raspberry Pi, a couple of sound cards or USB sound interfaces and perhaps some additional switching hardware to create compliant EAS that would be a fraction of the cost charged by the major manufacturers.  

The bottom line is that all LPFM stations are required to comply with the EAS decoder requirements in Part 11 of the rules and every LPFM station needs to be equipped with EAS capable of at least decoding.  It is also an LPFM station's responsibility to watch for news updates from the FCC such as the releases they issued to announce this test. Details about the EAS test were also relayed by REC, Prometheus and other LPFM advocates through various channels including social media, direct e-mail and website.  There was also coverage of the testing in Radio World and other trade publications and blogs. Because of the segmentation of LPFM, we can't reach everyone.  This is why it is important that LPFM stations, proactively seek updates from groups like REC and Prometheus for updates on the service. 

For now, I will be requesting that the Public Safety and Homeland Security Bureau give LPFM a "recount" and accurately report the percentage of participation by LPFM stations and look further into the methods that we can take to lower the costs for LPFM and other small stations to be able to better afford and maintain a compliant EAS system.

Media contact: Michelle Bradley, REC Networks, 202-621-2355.

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