In addition to the November 13, 2017 deadline that LPFM stations have for the National EAS Test, did you know there was a second reporting deadline for all EAS participants? On March 23, 2016 without a lot of fanfare and zero-involvement from any LPFM interest, the FCC adopted an order that established certain reporting requirements from all EAS participants (including LPFM stations) to their State Emergency Communications Committees (SECCs).
Specifically, by November 6, all EAS participants are supposed to provide their SECCs with the following information:
- A description of any actions taken by the EAS Participant (activing individually, in conjunction with other EAS participants in the geographic area, and/or in consultation with state and local emergency authorities), to make EAS alert content available in languages other than English to its non-English speak audence(s).
- A description of any future actions planned by the EAS Participant, in consultation with state and local emergency authorities, to provide EAS alert content in languages other than English to its non-English speaking audience(s) along with an explanation of the EAS Participant's decision to plan or not plan such actions.
"This is the first I have ever heard about this" was the overwhelming response by LPFM stations in an informal poll conducted by REC in regards to an August 15, 2017 Compliance Guide which was never publicized in the FCC Daily Digest publication. As a result of this lack of publicity about this proceeding by the Commission towards non-corporate owned LPFM stations that do not have staff attorneys, REC is asking for relief.
Citing the lack of publicity of this proceeding and the lack of involvement from LPFM interests, REC Networks has filed a motion with the FCC to request an exemption from reporting for LPFM stations or in the alternate, an extension of time. Unlike full-service broadcasters and cable television providers, LPFM stations are not required to originate and encode EAS messages but instead are only required to be equipped with EAS decoders. This places LPFM stations at the "end of the chain" and therefore would limit their influence on the languages carried by upstream (LP-1 and LP-2) EAS originators.
Due to the nature and segmentation of LPFM stations, there is no true membership organization that represents LPFM stations at a whole. Those who are watching out for LPFM (including REC) are volunteers without any retained legal counsel available. REC is aware that a few LPFM statations were advised of this by virtue of their memberships in state broadcaster associations. Since LPFM was never at the table, we had no say.
LPFM stations that are able to make this statement by the deadline are encouraged to do so. Information about your SECC should be located in your state EAS plan which each LPFM station should have with their EAS handbook at their control point.
A list of SECCs (and EAS plans) can be found here:
https://www.fcc.gov/public-safety-and-homeland-security/policy-and-licensing-division/alerting/general/state-eas-plans
Unless we hear otherwise, there is a deadline of November 6.
