Broadcasters' Desktop Resource

... edited by Barry Mishkind - the Eclectic Engineer    

Magnum Towers Inc.

The Part 11 Re-write

Overview of the FNPRM    Questions and Answers    How to file your comments

The announcement on May 26th of the release of the Third Further Notice of Proposed Rulemaking finally allows everyone to see what the FCC is thinking in terms of changes for Part 11.  And there is a a lot to chew on - 110 pages. As of June 20th, it was published in the Federal Register - starting the 30 day comment period ending July 20th.

Here are some initial thoughts shared by someone who has done a quick initial look at the FNPRM. More will be added to this page as the dissection continues.

Some quick notes.  The notice is 110 pages long and linked here.

Given the planned 30/45 period for comments and reply comments on an NPRM we are already well into July without any new Rules.

If certification requirements are added for new equipment there it would appear there will likely be another extension to the "180-day clock."

Quick review of EAS 3rd NPRM:

1. Must have equipment to Convert CAP formatted messages to EAS compliant messages.

2. Proposes using RSS for distribution of CAP messages. Look at page 30 of the notice for more details.  Also propose that state servers be RSS push devices rather than other means of distribution.

3. Comment: Permit intermediary devices or converters from CAP to EAS?

4. Comment How to certify all in one CAP/EAS devices.  Look at paragraph 49 proposal to have the EAS/CAP encoders capable of creating CAP messages.  WHY? (Unless installed at emergency center) would appear to eliminate ability to use cap converters or make them more costly then necessary...would require all devices have computer (i.e. keyboard/mouse/monitor) attached somehow.

5. Comment Should also require certification of the CAP converters as separate devices?

6. Extend 180 day Rule start 9 /30?

7. Propose: Must-carry governor's message but only if in CAP format.

8. Comment sought: New Governor must-carry code?

9. Comment sought: Governor must carry to carry location codes?

10. Propose/Comment sought: Simplify EAN procedure?

11. Eliminate EAT and replace with EOM?

12. Comment: should (2-tone) attention signal go away?

13. Comment: How can CAP improve access for disabled?

Much more to digest.


Information on offering comments

The time has come!  The FCC wants to hear from folks about the Part 11 (EAS) Rules and procedures that need changing.

Comments to the FCC are due by July 20, 2011, and reply comments are due by August 4, 2011.

§     Electronic Filers:  Comments and reply comments may be filed electronically using the Internet by accessing the ECFS: or the Federal eRulemaking Portal:   Filers should follow the instructions provided on the website for submitting comments. 

§     For ECFS filers, in completing the transmittal screen, filers should include their full name, U.S. Postal Service mailing address, and the rulemaking number.  Parties may also submit an electronic comment by Internet e-mail.  To get filing instructions, filers should send an e-mail to  and include the following words in the body of the message: “get form.”  A sample form and directions will be sent in response.

§     Paper Filers:  Parties who choose to file by paper must file an original and four copies of each filing.  U.S. Postal Service first-class, Express, and Priority mail should be addressed to 445 12th Street, SW, Washington, D.C. 20554.

The Docket number is 04-296

Dale Gehman says: "I would encourage everyone with a passion for a logical advancement of the Emergency Alert System to develop and submit informal comments as the outcome of a revision of Part 11 (EAS) Rules will have a significant functional and monetary impact upon every Broadcaster.

"Here is the link address to the Public Notice document:"


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