Before the Federal Communications Commission Washington, D.C. ...

Federal Communications Commission FCC 02-64submit that it is unlikely that low-cost, FCC-certified decoders will become available. 156 HollyAnnestates that if it produced and certified an EAS decoder, it does not anticipate any reduction in costbecause of the technology it uses in the manufacture of its encoder/decoder. 157 Sage indicates that themarket represented by LPFM stations is too small to warrant significant investment by existing or newEAS vendors of certified decoders. 158 TFT states that it has no current plans to certify a decoder onlyunit because only minimal savings would be realized from removing the encoder from its certifiedencoder/decoder unit and still complying with the certification requirements for decoders. 159 However,TFT notes that it currently manufacturers a low-cost, non-certified decoder, the TFT Safety 1st, for thecommercial and industrial markets not subject to Part 11 requirements. The TFT Safety 1st is notcompliant with the Part 11 requirements for EAS decoders because it does not have a digital input anddoes not have the ability to record and store the last ten message header codes received. 160 TFT urges theCommission to relax the certification standards for EAS decoders because that will permit themanufacture of low-cost decoder-only units. 161 Vela, a manufacturing partner of TFT, acknowledges thatthe TFT Safety 1st lacks two of the capabilities to make it fully certifiable under the Part 11 requirementsfor EAS decoders. 162 However, Vela states that when the TFT Safety 1st is combined with Vela’s EAScontroller components, Vela and TFT are able to provide a fully compliant decoder-only solution for thecable market. Vela states that if the Commission authorizes small cable systems to comply with the EASrules by installing a decoder only, it plans to submit this decoder-only system for certification in the firstquarter of 2002. Vela maintains that the cost savings to small cable systems of this decoder-only systemwill be significant. By eliminating the encoder function, Vela asserts that an EAS decoder-only systemcan reduce the cost by 64% over what a cable operator would spend for an encoder/decoder unit.71. After reviewing the supplemental comments, we conclude that the public interest will beserved by amending the Part 11 rules to permit cable systems serving fewer than 5,000 subscribers to usean FCC-certified decoder, if such a device becomes available by October 1, 2002, in lieu of anencoder/decoder unit. If FCC-certified decoders are not available by the October 1, 2002 compliancedeadline, cable systems serving fewer than 5,000 subscribers will continue to be required to comply withthe EAS rules by installing an encoder/decoder unit. We agree with the American Cable Association(“ACA”) that authorizing the use of decoder-only units will, to the extent that such decoders may becomeavailable at a lower price than encoder/decoder units, benefit the public by reducing costs for small cablesystems in meeting the October 1, 2002 compliance deadline. 163 Similarly, we agree with the WirelessCommunications Association International, Inc. (“WCA”) that permitting small wireless cable operatorsto use decoder-only units, to the extent that such decoders may become available at a lower price than156157158159160161162HollyAnne Supplemental Comments at 1; Sage Supplemental Comments at 1.HollyAnne Supplemental Comments at 1.Sage Supplemental Comments at 1.TFT Supplemental Comments at 4.Id. at 5.Id. at 6-7.Vela Supplemental Comments at 2.163ACA Supplemental Comments at 1.28