Station Compliance›FCC Watch

Nothing new on § 11.35(d) for a third week running, and still no fine has been issued under the rule. But the Enforcement Bureau did issue an EAS notice this week, and it is the kind of finding any small station could get on an ordinary inspection.

The Montana notice

On October 23 the Bureau's Region Three office issued a Notice of Violation (DA 26-1148) to BMG Billings, LLC, licensee of KEWF, KRPM, KYSX and KRSQ in Billings. An agent from the Denver office inspected the stations on July 29 in response to a complaint and found three things:

1. The wrong monitoring source. The EAS logs showed the stations monitoring a secondary source that was not assigned to them and was not in the Montana State EAS Plan (§ 11.52(d)(1)).
2. No signed test records. The stations could not produce signed log entries showing their EAS tests were run (§ 73.1820(a)).
3. No one caught it. The chief operator's weekly log review should have found the wrong source and fixed it, and did not (§ 73.1870(c)).

There is no fine in the notice. The licensee has 20 days to explain each violation, say what it has done to fix it, and give a timeline, all under penalty of perjury. The Bureau notes that the notice does not rule out a forfeiture later.

What to take from it. None of this is about hacking or passwords. It is the plain paperwork of EAS, and it is what an inspector looks at first. Ten minutes this week is enough to check it:

• Open your state EAS plan and confirm the two sources your unit monitors are the two assigned to you. Plans change, and a source set up years ago may no longer be on the list.
• Look at last month's EAS log. Every weekly and monthly test, sent and received, should have an entry, and someone should have signed the weekly review.
• If a test was missed, the log should say why.

This matters more than usual this month. The National EAS Test on November 17 only reaches you if you are monitoring the right sources, and Form Two asks what you received.

Software EAS

No Commission action. The record closed September 29. The October 5 entry covers who said what.

Equipment

No new firmware releases or security advisories from the major EAS, codec or transmitter makers this week. SBE's minimum firmware versions for the national test (Sage ENDEC 96.00, DASDEC 54.00) are in the October 12 entry.

What is next

Form One is due this Friday. Your monitoring assignments are on it, so if the check above turns up a source that does not match your state plan, fix the unit first and then file.