The author is with law firm Fletcher Heald and Hildreth, on whose blog this article originally appeared.
Attention, all you EAS participants. The Commission has formally opened up its new EAS Test Reporting System (ETRS), which means that you’ve got until August 26, 2016 to get into the site and complete Form One. And while you’re at it, you might also want to take a gander at the draft of a New and Improved 2016 EAS Operating Handbook that the Communications Security, Reliability, and Interoperability Council (CSRIC) has developed. It’s still a work in progress, but the FCC wants to know what you think about it.
First, ETRS. As we reported last year, following up on its First-Of-A-Kind 2011 Nationwide EAS Test, the Commission decided that it needed a better mechanism for getting feedback on the effectiveness of its tests. Thus was born the ETRS. First announced back in June of last year, the new system wasn’t ready for preview until April of this year. The preview consisted of a public notice full of screen grabs showing what the ETRS site would look like if it were up and running, which it wasn’t, because the site itself didn’t go live until June 27.
Now that it’s live, all EAS participants are required to access it. There you’ll be able to obtain your own ETRS account credentials, with which you will then get into the system and complete Form One. Simply go to the ETRS page on the FCC’s website where you will find a link to the ETRA Registration Page (or you can cut to the chase and go straight to the Registration Page at this link). At the Registration Page you’ll be asked for identifying information (including name, address, phone numbers, FRN and FRN password). When you submit all that, you’ll receive an email with your ETRS account credentials and a link to the ETRS log-in page. Once you have headed to that link and logged in, you’ll find instructions for completing Form One.
The Commission cautions that care should be taken in accurately providing the EAS participant’s legal name during the registration process. It also instructs that any EAS participant “owned by a larger entity should accurately enter the owning entity’s legal name in the Owner of EAS Participant field in Form One”. Participants with multiple facilities will also be able to appoint a “coordinator” who would be able to access and revise data for all filers using the same FRN.
Since we here in the CommLawBlog bunker aren’t EAS participants, we haven’t tried to finagle our own ETRS account credentials, so we can’t tell you exactly what the log-in page and Form One look like. But presumably the screen grabs provided by the Commission last April are accurate.
Bottom line, ETRS-wise: If you’re an EAS participant, you’ve got until August 26 to get your Form One completed and filed. (You’ll have until September 26 to make any corrections, should that be necessary.) And remember, the next nationwide EAS test is currently scheduled for September 28.
Now, about that draft EAS Operating Handbook.
The Handbook is an FCC publication designed to provide guidance to the folks on duty about what they’re supposed to do when an alert rolls through. The Commission’s rules require that each EAS participant have a copy of the Handbook at “normal duty positions” (or wherever a station’s EAS gear is located).
The problem, though, is that the Handbook has not kept up with the times. (CSRIC concluded, somewhat harshly, that “[t]he current handbook is obsolete and contains inaccurate instructions.” Ouch.) Recognizing this, the FCC delegated to CSRIC the chore of recommending “textual and visual modifications” to make the Handbook “suitable” for all EAS participants, including particularly those that are “rural, smaller and less resourced”.
CSRIC has come up with a draft revision of the Handbook that would be customizable for each individual EAS participant. A copy of CSRIC’s handiwork may be found at Appendices A and B of its Final Report on the project (at PDF pages 12-46). As envisioned by CSRIC, the Handbook would be available online for download, with various blanks to be filled in by the responsible person at each EAS participant. The idea is that the Handbook would include information to guide ALL types of EAS participants – and that each individual participant would be responsible for customizing its own Handbook to that participant’s particular circumstances.
This is obviously a novel approach, but one that might well serve all EAS participants. The Commission has not yet signed on to it, though. Instead, it’s looking for comments from the EAS universe. We encourage one and all to take a close look at what CSRIC has proposed and to let the FCC know your thoughts. The deadline for comments will be 15 days following publication of the FCC’s public notice in the Federal Register. That’s not much time, so you might want to take a look sooner rather than later. And you can check back here for an update as to the date of publication (and consequent comment deadline).