On September 8th, the CBA jointly filed, with all the state broadcast associations, a letter to the FCC regarding EAS and the national test.
In summary, the following arguments were made:
(1) The State Associations support the NAB’s position that “000000” should be used as the National EAS Location Code;
(2) The State Associations also support the NAB’s position that the National Periodic Test Code (NPT), as currently configured, is the only reasonable way to accommodate another nationwide EAS test in the next 12-15 months as opposed to using a reconfigured NPT that mimics an Emergency Action Notification (EAN);
(3) The FCC should provide stations with clear guidance regarding FEMA/IPAWS logging requirements;
(4) The FCC should consolidate its national EAS electronic filing forms to make it easier for stations to file their test results, including consolidating the forms and permitting the filing of “batch” reports on behalf of multiple stations should they choose to do so, and to allow for a streamlined waiver process for those few stations that do not have Internet access; and
(5) The FCC should grant stations the right to opt out of a cable system’s EAS override.