Like all FCC rules in the CFR, the trick is learning which parts you can ignore and what parts you have to pay attention to. Your question, though, is pretty broad and deals with a very key issue; the things the FCC nails people on the most are indecency, public files, station logs, tower lights and EAS; the latter four are all interconnected.
STATE PLAN & WHO TO MONITOR
Let's start with the EAS State Plan. You will not find the Massachusetts State Plan anywhere on the web. It's controlled by the Massachusetts Emergency Management Agency (MEMA) and they consider it confidential information. Each copy is meant to be "controlled", as in you can't just request extra copies for the station. For the stations I work with, I spoke with Tom Muise at MEMA (508-820-2023) to get my copies...I'd suggest giving him a ring. You WILL need a copy of the State Plan to put in your public inspection file. However, I can tell you that for the Worcester area - there are two stations you MUST monitor: WSRS 96.1 and WBZ 1030AM. If you choose, you can monitor other sources, including other radio stations or, more commonly, NOAA/NWSweather radio (I'm guessing the Nat'l Weather Service repeater WXL93 in Paxton on channel 162.550 is probably the best to monitor.
YOUR EAS CODEC OR ENDEC
Monitoring is accomplished simply by tuning a radio and feeding the audio output of the radio into your EAS encoder/decoder (aka "endec" or "codec"). The endec's are broadcast-specific devices and if you haven't bought one already, you must do so ASAP (all stations were required to get one in 1997). NOTE: These are NOT the same thing as the old EBS receivers/codecs. You can get them through www.bswusa.com
- the Sage ENDEC (made by Harris) is a little more expensive but is far far far far FAR easier to install and use than most other models (Burk, TFT, Gorman-Redlich). While your station doesn't really ORIGINATE events, by definition you must be able to encode the data tones (commonly called "data burps"...they sound vaguely like a modem or fax machine) on your airwaves so all stations must have EAS encoders/decoders. There are two exceptions - LPFM licenses (if your call letters are something like WXYZ-LP, then you're an LPFM...otherwise you're not) are only required to have decoders. But decode-only EAS units are uncommon and not really any cheaper than encoder/decoders...and it's just fine for an LPFM to have an encoder/decoder, too. The other exception is that Class D's may, if they file the proper paperwork, elect to become a secondary station for EAS. In such a case, they need only comply with the decoder side of EAS...but in the event of an actual EAS emergency, they would have to announce the emergency and then shut off the transmitter for the duration of the emergency. Very few stations elected to go this route...but I think WRBB at Northeastern is one. The specifics are in the State Plan.
RADIOS FOR MONITORING
While technically any radio will do for monitoring, but you'll want to get good radios and good antennas so as to get a clean audio feed. The kind you can get at Radio Shack (or Best Buy or most any consumer shop) are generally poor quality. I recommend investing in a pair of NAD Electronics C422 (www.nadelectronics.com
) - it's an excellent tuner and will fit in a rack (if you get a rack shelf). BSW (www.bswusa.com
) can recommend tuners for weather radios/NWS. Be prepared to spend money - a lot more than you'd normally spend for a radio for a dorm room or whatnot. However, more money does not *automatically* equal better radio...the Rolls tuners, for example, are notorious for poor reception. Ditto for the Burk receiver they sold as an accessory to their EAS units (which they don't sell anymore). Although at least with the Burk it was a convenient 1RU package even if the receivers were not good quality. If you've got an engineer on staff or contract, also consider asking them to rig up some car radios for this purpose. Car radios are well known to be much better tuners than most home tuners...the only downside to this idea is that you've got to take some extra precautions wiring the suckers with a power supply and a battery because 99% of car radios will lose all their settings in a power outage; it's far too easy to forget to re-tune your radio after an outage.
THE PATH OF THE EAS EVENT
Now, getting into what you actually have to do in case of an EAS event, I have to explain the theory a bit...what happens is the PEP (Primary Entry Point) gets a signal from the White House, FEMA, State Police, or other designated authority. The crew at WBZ then uses their endec to broadcast an alert. All the State Primary (SP) stations (like WBMX or WSRS) across Massachusetts that monitor WBZ will pick up this alert and, as quickly as they can will relay the alert. In turn, all the stations (like yours) monitoring the SP stations will pick up the alert...after which they have 60 minutes (that's a recent rule change - around the same time AMBER alerts / CAE came out) to relay (aka "forward") the alert themselves to all their listeners.
Required Weekly and Monthly Tests (RWT & RMT) follow the same path...with one difference. For RWT's only, you do not need to relay the RWT to your listeners...you only have to log it in your Station Log (that's an official term, not a generic one). However, at some random point during each week (excepting weeks when a RMT occurs) you must originate your own RWT and log that in the Station Log.
Weather alerts are a little different...they're controlled entirely by the Nat'l Weather Service and only broadcast on the NWS frequencies. Monitoring and participating in weather alerts is STRICTLY OPTIONAL. You may want to do it to give your listeners something of a better service, and also to give your DJ's more exposure to EAS alerts...but that can backfire. During the hot summers frequently thunderstorms will move across the state and trigger dozens of NWS alerts as it moves from county to county. That can get real annoying, real fast to both your DJ's and your listeners. YMMV.
The "big one" of EAS alerts...the EAN (Emergency Action Notification)...is also a little different. EAN's are when the US President is essentially taking over every radio & TV station in the country for a live broadcast. This has never happened in the history of EAS, but it always can happen at any time. When it happens, the EAS codec box will seize control of your program feed to the transmitter and insert the audio from the SP or PEP you're monitoring. That can happen with regular alerts too (like AMBER alerts) but the difference is that until the President issues an EAT (Emergency Action Termination) code, that seize stays in effect. Depending on the emergency, that EAT could be minutes, hours, days or years in coming...whereas with regular alerts it's effectively limited to 2 minutes.
HOW AUTOMATIC CAN I MAKE THIS?
Fortunately, most EAS codecs can be programmed to automatically relay any set of alerts/tests you feel are "critical" and the rest are not. Usually all alerts are automatically "logged" (most EAS codecs have a built-in printer, although they usually stink and you'll want to invest the $200-$400 in an external printer...TRUST ME ON THIS ONE!) so you can easily transcribe the information into the official Station Log. The one exception? Sending RWT's...those you must, by definition, initiate yourself. It's usually a one or two button affair, though...quite easy. Usually it's a good idea to jiffy up a script for the DJ to read before triggering the RWT (or any test/alert for that matter) so the listeners have some idea just what da heck are these odd "data burp" sounds they're hearing. :-)
If you run unattended any time of the day/night (i.e. "automation") then you'll want to ensure the bare minimum of required events will auto-forward: RMT's, EAN's, etc. Actually IIRC those two are the only two you MUST forward...save for maybe the EAN-related administration messages, but those are very rare. Anyways, the State Plan will tell you which you must do.
WHAT WAS THAT ABOUT THE TESTS AGAIN?
No problem - the Required Weekly Tests (RWT) are usually sent by the PEP/SP on Tuesdays near 3pm or 3am...it alternates from week to week. You just need to log its reception in the Station Log. Nothing more.
You can send an RWT whenever you want, although you're supposed to vary it randomly from week to week. Send as many as you like, too...just one per week is required but there's no upper limit. Just remember that ALL events of EAS, even extra tests, must be logged in the Station Log.
Usually the first Tuesday of every month, around 11:45am, is when the Required Monthly Test (RMT) is sent by the PEP/SP. You must relay/forward the RMT within 60 minutes of receiving it. Most EAS codecs give you the ability to forward manually whenever the DJ wants after a RMT comes in, but the codec will automatically forward it after 60 minutes (if you have older firmware, it'll do it after only 15 minutes...and you should get that firmware updated anyways). That way the DJ has time to wait for a song to end, get a script ready, read the script, trigger the RMT, then go back to the music...instead of the RMT just rudely cutting in and interrupting the middle of a song.
WHAT'S THIS STATION LOG?
The Station Log is an official log of things the FCC requires you to log. Used to be you had log all kinds of crap: transmitter readings, program logs, etc. These days the only things that have to be in the Station Log are logs of your tower lights (if you have any AND only if you are the owner of the tower) and EAS events. That's it...unless you're a directional AM station - they have a little bit more to log, but you said you were a NCE Class A FM.
For more info on how to keep the logs, see the rules:http://sujan.hallikainen.org/FCC/FccRules/2006/73/1800/http://sujan.hallikainen.org/FCC/FccRules/2006/73/1820/
A few key points. The Station Log is NOT REQUIRED to be in your Public Inspection File. In fact, it should not be kept there because these days, the only people who want to see your Public File are FCC inspectors and people looking to dig up dirt on you. While the former gets to see the Station Logs anyway, there's no need to give ammo to the latter. I recommend having two file cabinets - one that locks - next to each other. One is the Public File, the locked one gets the Station Logs. That way they're conveniently close for staff members and FCC inspectors, but you can protect yourself from dirt-diggers.
You're required to keep Station Logs for two years (at a minimum) on a rolling basis (monthly, I believe). I suggest keeping 2.5 years worth and removing the oldest month whenever you add a new month. Shred the logs that're being discarded - that's confidential information on there!
Station Logs must be reviewed AND SIGNED by the Chief Operator (CO) each and every week (see rule http://sujan.hallikainen.org/FCC/FccRules/2006/73/1870/
esp. paragraphs (b)(2), (b)(3) and (c)(3) Remember that to review the log is NOT to simply read it and sign it. You are legally obligated to take correct actions when a log entry shows an out-of-tolerance condition or situation. Or when there's no log entry. Only after you have figured out the reason, taken corrective action, and documented all that on the Station Log, may you actually sign it. The Chief Operator is the one the FCC goes after for improper logs so make sure your CO is someone with the authority to make changes - up to and including a procedure for disciplinary action for staff - when the logs indicate problems.
While you don't HAVE to combine an operator-on-duty log with your Station Log, I suggest doing so because it makes it a lot easier to track who was responsible for a log being incorrect or whatever.
To make things easier for the CO, it's not a bad idea to have logsheets that represent an entire week on one sheet. But if you prefer one sheet for each day, that's fine, too.
You can also still take transmitter readings if you want...it's a good idea even if it's not required. The FCC looks favorably on it and it can save your neck when someone accuses you of broadcasting out-of-power or whatever and you've got logs to refute the claim. Plus it keeps your DJ's more aware of what's going on at the transmitter...keeps it fresh in their memory.
That's okay...EAS is confusing stuff. The rules have to cover some 11,000 radio stations (never mind TV) and they all do things differently. I just banged out the above while watching the Simpsons last night and I'm going from memory, but I think I got most everything right.
I suggest you consider hiring a professional engineer who knows this stuff to come out and help you interpret the rules for your situation specifically; help you write up sample EAS scripts, train staff, get the monitoring radios tuned right and the control wiring done, etc etc etc. I personally happen to be an engineer like that, so yes, I'm tooting my horn a bit. But I'm based just north of Boston. I don't mind driving out to Worcester but you may want to look for someone closer to home, too.
Either way, feel free to give me a buzz - there's a good chance I'll know someone near you, and I don't mind chatting for a bit about college radio. I'm just a real sucker for it. :-)
- Aaron Read
- FriedBagels Technical Consulting
- (617) 512-7657
> I have somewhat of a newbie-ish question as I am in the new
> position to oversee engineering operations at our class A
> non-com edu station in MA.
> I am a bit confused over the whole EAS system. I have read
> the FCC rules/manuals many times, and there are just a few
> things I still don't understand.
> What makes a station one that is monitored? We monitor 3
> stations and NOAA.
> What is it that we are exactly required to forward (ie,
> there are many different types of weather alerts, etc).
> Also, is it true that the station we monitor should only
> issue 1 RWT, but we can issue more if necessary since no one
> is monitoring us?
> Maybe someone could provide a simplified understanding of
> the whole process, I would greatly appreciate it. The FCC
> rules don't seem to differentiate well enough between
> primary stations who encode messages and stations like ours.