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Cole Questions FCC’s Math

Wonders if 3.5 million people will fill out EAS forms at 90 seconds average

Broadcast attorney Harry Cole is scratching his head again over some numbers from the FCC.

Writing in the blog of Fletcher Heald & Hildreth, Cole says the FCC has estimated that the number of respondents using the online EAS report form will be 3,569,028.

“Can we all agree that it’s seriously unlikely that there will be 3.5 million people, or stations, or reporting entities, filing EAS reports?” asked Cole (who is also an RW columnist).

He also questioned the FCC’s latest paperwork “burden estimates.”

“Back in September (according to the Federal Register), the FCC advised OMB that the ‘estimated time per response’ for completing the online nationwide EAS test report was (and we’re not kidding here): ‘.034–20 hours,’” Cole wrote.

According to Thursday’s notice, that number has shrunk to “0.0229776 hours.”

“Take a minute to wrap your mind around those numbers,” he wrote.

“According to the first estimate, the FCC was figuring that it would take a responder somewhere between 2.04 minutes and 20 hours to get the report completed and filed. That’s probably a safe range — maybe a bit extreme on both ends, but certainly most folks should be able to get the job done somewhere between two minutes and 20 hours.

“But according to [Thursday’s] estimate, we’re all looking at a time commitment of just under 90 seconds (i.e., 1.378 minutes). Isn’t that a tad ambitious?”

Cole said, “Anyone who has tried to complete the report should know that, even with all the coordinates and FRNs and facility ID numbers and other necessary information readily at hand, it’s probably going to take longer than 90 seconds to file a single report.”

He concludes: “We have previously remarked on the FCC’s bizarre estimates in its Paperwork Reduction Act submissions. This latest batch does nothing to shore up our confidence in them — or in the Paperwork Reduction Act process as a whole.”

The Incredible Shrinking Nationwide EAS Test” (FHH blog)