As we all know, the FCC has been planning the second nationwide test of the Emergency Alert System for months. To monitor how the test goes, the Commission developed a whole new online reporting system – the EAS Test Reporting System (ETRS) – for which all EAS participants had to register separately a month ago. And for some reason, the Commission ordered all participants to file their preliminary post-test reports (a/k/a Form Two) by 11:59 p.m. (ET) on the day of the test.

So you might be surprised to learn that, about 24 hours before the long-scheduled test, the Commission posted the following information on its website:

To maximize the resources available to process Form Two filings, we recommend that EAS Participants file Form Two in accordance with the following schedule:

Facilities in Eastern Time Zone –
2:30 pm to 5:00 pm EDT

Facilities in Central Time Zone –
5:00 pm to 7:00 pm EDT (4:00 pm to 6:00 pm CDT)

Facilities in Mountain Time Zone –
7:00 pm to 8:00 pm EDT (5:00 pm to 6:00 pm MDT)

Facilities in Pacific Time Zone –
8:00 pm to 9:30 pm EDT (5:00 pm to 6:30 pm PDT)

       Facilities in all other time zones – 9:30 pm to 11:59 pm EDT

If you cannot file for your facilities at the recommended time, you may file at any other time. Relatedly, we urge all EAS Participants to submit Form Three no earlier than September 29.

Call us crazy, but that suggests that the FCC may not have confidence that its ETRS will be able to handle the surge of Form Two filings that the FCC itself ordered up. Does that inspire confidence in the planning at work here?

Whatever. The important take-home message is that, if you’re an EAS participant, you may want to time the filing of your Form Two to fit into the appropriate time slot, and also hold off on filing your Form Three for a couple of days. Or not. It’s not mandatory.