Latest edition of FCC Handbook features blank spaces galore to be filled in by EAS participants themselves.
Two days after we posted a reminder about the upcoming deadline for EAS participants to (a) register on the Commission’s new EAS Test Reporting System and (b) submit their Form Ones (or should that be “Forms One”?) through that system, the FCC’s Public Safety and Homeland Security Bureau has done likewise. And, as a bonus, the Bureau also released the latest and greatest edition of its EAS Operating Handbook … although it reads more like a Mad Libs book than an instruction manual.
In a public notice the Bureau has reminded one and all of not only the August 26 deadline (for registration and Form One), but also the follow-up deadlines for Form Two (September 28, 2016) and Form Three (November 14, 2016). (It also mentions in passing a “secondary test date” currently set for October 5, 2016 at 2:20 p.m.)
Note in particular the Form Two deadline. Since, as we all know, the next nationwide EAS test is currently scheduled for 2:20 p.m. on September 28, EAS participants will have less than 10 hours – i.e., from the end of the test sometime after 2:20 p.m. to 11:59 p.m. on September 28 – to get Form Two filed. Plan accordingly, but rest assured that Form Two shouldn’t take long to complete: according to a Bureau-provided preview, Form Two merely asks two yes/no questions, i.e., whether (a) you received the message and (b) you retransmitted it.
As noted above, the Bureau has also announced the release of the Commission’s new and (theoretically) improved EAS Operating Handbook. A copy of the Handbook is included as an attachment to the public notice, or you can find it here. Particular attention should be paid to this. A copy of the revised Handbook must, according to the notice, “be located at normal duty positions or EAS equipment locations when an operator is required to be on duty and be immediately available to staff responsible for administering EAS tests.” And don’t think you can get away with using any previous version of Handbook: this new one supersedes all earlier versions and must be in place in time for the September 28 test. Let the downloading and printing begin!
As we reported in June, when the draft revision of the Handbook was first released for comment, the need for an updated version was prompted at least in part by the observation of the Communications Security, Reliability, and Interoperability Council (CSRIC) that the then-most-recent version of the Handbook was “obsolete and contain[ed] inaccurate instructions”. The new version seems to avoid those problems by opting not to provide instructions in the first place. As explained in the very first paragraph of the Handbook, helpfully marked “IMPORTANT”:
In order to optimize use of the handbook, blank spaces are provided for EAS Participants that may wish to tailor the handbook to accommodate their own individual procedures prior to posting. Blank spaces are provided for EAS Participants to individualize the handbook.
And sure enough, blank spaces abound throughout the Handbook, making it more of a do-it-yourself effort than an FCC-provided regulatory roadmap. And if you find yourself needing help, the Commission doesn’t go out of its way to invite inquiries. Instead, the Handbook suggests that
[a]ppropriate State or Local Emergency Communications Committee personnel and the manufacturer of your facility’s EAS device have additional information that will assist you in utilizing this Handbook.
So if you happen to be the person in charge of EAS compliance at an EAS participating facility, you’ve got your work cut out for you. Print out the Handbook and start filling in the blanks. Unfortunately, neither the Bureau nor the Handbook itself provides any detailed guidance about precisely what information should be inserted into the blanks. While, obviously, each participant’s equipment configuration and staffing set-up may entail some idiosyncratic aspects requiring personalized knowledge, it might have been nice if the Bureau had offered at least some hints at how it expects participants generally to summarize their internal procedures. Instead, EAS participants have been given something of a tabula rasa.
Further complicating things is the fact that the Handbook version the FCC has released doesn’t appear to be set up for on-screen completion. Presumably, anyone practiced in the PDF arts should be able to create a computer-fillable copy of the Handbook. Failing that, you can always kick it old school with a typewriter, or older school with pen and paper.
However you choose to roll, though, you’ve got until September 28 at 2:20 p.m. to distribute the 2016 edition of the Handbook to all EAS duty positions.