In newly added “note”, FCC requests – but does not require – reports on translators, boosters and satellite stations

It looks like the Commission has revised the instructions for the electronic filing of reports on the Nationwide EAS Test. We have just received word from our friends at the NAB that the Commission has inserted the following “special note to broadcasters” in the introduction to those instructions:

Special Note for Broadcasters: For Form 1, Form 2, and Form 3, Broadcasters are encouraged to provide information only for their main, full-power facilities. As described below in the instructions for Form 3, we request that Broadcasters provide information on their translator, booster and/or satellite facilities so that we may obtain as complete a picture as possible of the extent of EAN dissemination. Broadcasters may note in the Explanation field of Form 3 that they use or own such facilities and may submit information about their translator, booster and/or satellite facilities via paper submission (e.g., Excel spreadsheet). If submitting a paper filing, Broadcasters are encouraged to include each facility’s FCC-issued Facility ID number, the latitude and longitude of the facility, and the main, full-power facility from which it should have received the EAN.

So all you translator/booster/satellite licensees – if you feel like it, you may provide information about your translator/booster/satellite facilities as part of your follow-up report on the Nationwide EAS Test. The Commission would presumably appreciate it if you did, especially if you’re aware of any problems that might have cropped up during the test. But for now, at least, the FCC is merely “request[ing]” that you do so. (For what it’s worth, it’s not clear that the Commission could require the filing of this additional information without first clearing that with OMB, but stranger things have been known to happen.) 

Note that the new language seems to say that, if you do choose to tell the Commission about translator/booster/satellite experiences in the Nationwide Test, you will have to do that on paper (although you’re supposed to give the Commission an electronic tip – in the “Explanation” field in Form 3 of the on-line report – that you may be submitting such a paper report). Such a supplemental report is still expected to include the site coordinates for each station (including translators, etc.). While the new note doesn’t say so, we’re guessing that the Commission will be looking for those coordinates in decimal form, using NAD27.

The fact that this change has been made within 72 hours of the test is a bit discomforting, although it appears to be par for the course.  (Truth be told, though, the Commission did give us the heads up last Thursday that we might want to be on the lookout for “significant developments” between then and the November 9 test). It’s also discomforting that we learned about this from the NAB, and not directly from the FCC. Indeed, once we had gotten wind of the change, we checked the FCC’s special Nationwide EAS Test webpage and could find no obvious notification about the change (but if you access the on-line instructions, the new language is definitely there).

We’ll try to keep you posted about further changes, if and when we find out about them. Check back here for further updates.