LPFM Advisory Letter #9 (Fourth Update, 08/03/2023) – EAS National Periodic Test

Original version – 05/05/2021 / Updated 06/11/2021 / Second update 07/07/2021 / Third update 06/08/2022 / Fourth update 08/03/2023

The Federal Emergency Management Agency (FEMA) has announced that there will be a National Periodic Test (NPT) of the Emergency Alert System (EAS) in 2023.

The test is scheduled for October 4, 2023 at 2:20 PM EDT.  The backup date is October 11, 2023 at 2:20 PM EDT.  The backup date is only used if there is a major event or any other reason why the October 4 date can’t be used.

LPFM participation in the NPT is required

As a broadcast licensee, your station has responsibilities.  Compared to full-service broadcast stations, LPFMs do not have as many of those responsibilities.  One of those is being equipped with a certified EAS decoder that is properly configured for your geographic operational area including reception of the designated LP-1 (lead primary) and LP-2 stations as well as an internet connection to receive alerts from the Integrated Public Alert and Warning System (IPAWS) and that your equipment is properly logging the received alerts, and the station is monitoring the logs and taking action when alerts are not received.

Preparing for the NPT

To assure that your station is working, not just for the NPT, but for any alerts, stations need to:

  • Assure that the station has a certified EAS decoder (or decoder/encoder) and that the unit is properly powered up and connected in the audio chain.
  • Review the State EAS Plan specific to your station’s operational area to determine monitoring assignments.
  • Check the radios for your EAS to assure they are tuned to at least the LP-1 and LP-2 stations on your State EAS Plan.
  • Assure that your EAS is configured to forward alerts from the counties (FIPS codes) that your station places a signal in and that appropriate event codes are being forwarded in compliance with the FCC rules (EAS, RWT, NPT) and your state’s EAS Plan.
  • Check to make sure that your EAS decoder has a supported firmware version (check with your EAS manufacturer).
  • Check to make sure the EAS decoder has internet connectivity and that the security certificate is current (If there is a security certificate issue, please check with your EAS manufacturer). 
  • If your EAS is remotely located (at the transmitter), make sure you can access your EAS remotely and that protections are put in place to prevent unauthorized access.
  • Make sure that you have an official FCC EAS Handbook at a control point (such as near the mixing board).
  • Check the EAS logs on a weekly basis to assure that your decoder is receiving weekly or monthly tests (RWT or RMT) from all three monitoring sources (LP-1, LP-2 and IPAWS).

FCC Forms and Filing Deadline Dates

The process for the NPT involves three different filing tasks by each broadcast licensee.  These forms will be filed in the FCC's EAS Test Reporting System (ETRS).

  • Form One is an initial filing that includes basic information about the station, the type of EAS decoder and firmware version, the location of the EAS decoder, monitoring assignments and the EAS operational area that the station serves.  The deadline for filing Form One is September 15, 2023.  Note: Stations that have already filed their Form One for the 2022 NPT that was due on February 28, 2023 only need to update their Form One that is already on file if there have been any changes to the station since that filing.
  • Form Two is filed in the hours following the NPT.  On this form, the station will simply state whether or not they received the test and whether the station's EAS decoder forwarded the test to go over the air.  The filing deadline for Form Two is October 5, 2023.  
  • Form Three expands on the result in Form Two and asks additional questions regarding any difficulties that were experienced in both receiving the test and forwarding the test and to identify any root cause to such difficulties.  The filing deadline for Form Three is November 20, 2023.

Time Share Stations

For an LPFM station that is on a time share and is scheduled to be off the air during the National Periodic Test, the station should fill out Form One as normal.  On the day of the test, they should check their EAS log to assure that the EAS decoder received the test.  Time Share Stations should fill out Form Two to indicate whether or not that they received the test and should answer that they did not forward the test.  After the test is over, if your EAS decoder saves the audio from the test, review the audio file of the recording for quality.  On Form Three, provide any comments about the quality of the recording or suspected reason why the station did not receive the test.  When giving the details on why the station did not forward the test message, state that the station was not on the air at the time of the test.

Accessing the ETRS

Stations that have previously participated in the NPT

Access the ETRS at
https://fccprod.servicenowservices.com/login_with_sso.do?glide_sso_id=10...

Log in with your CORES user name and password.  

Once inside the ETRS, select the form number that you want to file.

If you have a CORES user name but need assistance with the password, visit:
https://apps2.fcc.gov/fccUserReg/pages/reset-passwd-identify.htm

Stations that have never participated in the NPT before

If you do not have a username in CORES, then visit:
https://apps2.fcc.gov/fccUserReg/pages/createAccount.htm

Access the CORES system with your CORES username and password:
https://apps.fcc.gov/cores/userLogin.do

On the CORES main menu, click on "Associate Username to FRN".

The system will ask for the FRN and ask you to enter a brief comment about your request, then click [Continue].

If there is a password associated with the FRN, the system will ask you for that password.  Once you enter the correct information, the FRN will be associated with your CORES username.

Access the ETRS at
https://fccprod.servicenowservices.com/login_with_sso.do?glide_sso_id=10...

Log in with your CORES user name and password.  

Once inside the ETRS, select the form number that you want to file.

If you have a CORES user name but need assistance with the password, visit:
https://apps2.fcc.gov/fccUserReg/pages/reset-passwd-identify.htm

REC Service Offering for the NPT

Like in previous years, REC Networks will provide LPFM stations (as well as full-service stations) with NPT filing services.  REC's fee to support this year's forms is $150 and is payable prior to filing Form One (if Form One needs to be filed) or by September 7, 2023 for stations that had already filed Form One in 2023 themselves or through someone else.  Payment may be made securely online using a major credit or debit card.  Payment by check is also possible with prior arrangement with REC.  Money orders are not accepted.

To engage REC Networks, please send an email to lpfm@recnet.com and make sure that "NPT" or "EAS" is in the subject line.

Stations engaging REC will need to contact us by email following the test to provide answers to the simple questions required for Form Two.  Interaction for Forms One and Three can take place at any time prior to the designated deadlines.

REC clients who paid for the Form One filing in early 2023

Those stations that already paid $150 in early 2023 for the Form One filing will not be required to pay again for this year's ETRS.  All such clients will be contacted by REC directly to advise of the test and to provide reporting instructions.  Please make sure that in the CORES system, that you still have etrs2018@recnet.com associated with your FRN.  If not, it will need to be added back in. 

All Broadcast stations (LPFM and Full-Service) must participate in the NPT

Providing emergency alerting is one of your station’s most important priorities.  Please make sure you are participating.  Help LPFM shine this October.

Thank you for your support of EAS, and REC!

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For more information

For legal questions, please contact your attorney.  With other questions including information not construed as legal advice, please contact REC Networks.  REC can handle transfer of control applications.  We can also handle most assignment applications, however, we will not be able to draft Asset Purchase Agreements as those are binding contracts that must be drafted by attorneys.

References

This Advisory Letter contains some interpretations and positions that have either not been reviewed by a qualified attorney nor tested in case law.  This document does not replace the services of a qualified attorney and therefore does not construe legal advice.  Only a qualified attorney can provide legal advice.

Originally written on May 5, 2021.  Revised August 3, 2023.

Michelle Bradley, CBT at REC Networks.

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