Station Compliance›Equipment›Television

The scope language, and why it reaches further in television

The rule covers three things: EAS equipment, studio transmitter link equipment, and — the phrase that does the work —

any remotely managed equipment that routes, processes, or inserts content into the transmission of the EAS Participant's programming

In radio, "inserts content" mostly means audio: the automation system, the processor, the RDS encoder. In television it means audio and video, and television has a legal obligation that forces a content-insertion device into the signal path whether the station wanted one or not.

The device nobody counts: the crawl inserter

Under 47 CFR § 11.51(d), a television station must transmit a visual EAS message carrying the originator, event, location and valid time period. It has to appear at the top of the screen or somewhere it does not interfere with other visual messages, be readily readable, not overlap or run off the display, and appear in full at least once during the message.

Something has to put those words on the picture. That device — a character generator, a crawl inserter, a master control keyer, or the EAS box's own video output — is inserting content into the transmission of your programming. That is the rule's own language, not an interpretation.

In scope in a typical television plant

Work through this as an inventory. For each device the questions are the same three: is it remotely manageable, does it still have a factory or shared password, and is it reachable from outside the building?

ATSC 3.0 raises the stakes rather than changing the rule

When the Commission authorised ATSC 3.0 it required 3.0 broadcasters to comply with the EAS rules, and the current rulemaking record treats 3.0 as a route to better alert geotargeting. None of that changes what § 11.35(d) asks of you.

What changes is the attack surface. A 3.0 plant is an IP plant: gateways, scheduler, broadcast core, studio-to-transmitter links carried over IP, and management interfaces on all of it. The rule's third requirement — a firewall or comparable network segmentation limiting remote management access to authorised devices and users — is more work and more valuable in a 3.0 facility than in a legacy one.

The accessibility obligation that runs through the same equipment

Television carries an obligation radio does not: emergency information shown on screen must also be made available to viewers who cannot see it. Under § 79.2(b)(2)(ii), emergency information conveyed visually outside a newscast must be preceded by an aural tone and, since May 26, 2015, presented aurally on the secondary audio stream — conveyed in full at least twice, with intelligible text-to-speech.

That means your crawl and your SAP path are part of the same compliance story, running through the same character generator, captioning encoder and audio chain that § 11.35(d) now requires you to secure. Two rules, one equipment list.

The detail is in the article on § 79.2.

If time is short, work in this order

1. List every port-forwarding rule and DMZ host on the station firewall. Not just the ones that look broadcast-related. This removes more real exposure per hour than anything else on the list.
2. Find the crawl inserter and the EAS box's video path and check what credentials they hold. This is the device most likely to be forgotten and it is explicitly in scope.
3. Walk master control — switcher, automation, servers — and try the documented factory defaults rather than assuming somebody changed them.
4. Check the STL, microwave or IP, at both ends.
5. Segment the plant network from the business network, or put remote access behind a VPN. Either satisfies the third requirement.
6. Write down what you found and what you changed. Nothing gets filed — the record is for the next person, because staff turn over and the rule's obligations are ongoing.

What the rule does not ask of a TV station

• No filing. There is no certification, report or new recordkeeping obligation attached to § 11.35(d). If someone offers to file it for you, they are selling a filing that does not exist.
• No multi-factor authentication mandate. MFA appears as an acceptable alternative to a 15-character password, not as a requirement.
• No scheduled password rotation. Change defaults before use, and change on reason to believe a password is compromised.
• No specific product. "A network firewall or comparable network segmentation practice" is deliberately technology-neutral.