FCC Suggests Staggered ETRS Form Two Filing

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Pillsbury Winthrop Shaw Pittman LLP associate Joseph A. Cohen writes on the firm’s CommLawCenter.com blog that the FCC, via an e-mail to those registered in the ETRS for today’s nationwide test, has put in place a suggested staggered filing of Form Two, by time zone.


The FCC explains that the suggested Form Two filing by geography—the staggered filing times are not mandatory—is meant to “maximize the resources available to process Form Two filings.”

The suggested filing times are as follows:

  • Facilities in Eastern Time Zone – 2:30 pm to 5:00 pm EDT
  • Facilities in Central Time Zone – 5:00 pm to 7:00 pm EDT (4:00 pm to 6:00 pm CDT)
  • Facilities in Mountain Time Zone – 7:00 pm to 8:00 pm EDT (5:00 pm to 6:00 pm MDT)
  • Facilities in Pacific Time Zone – 8:00 pm to 9:30 pm EDT (5:00 pm to 6:30 pm PDT)
  • Facilities in all other time zones – 9:30 pm to 11:59 pm EDT

The voluntary staggered filing schedule is the latest move regarding the EAS test that Cohen questions.

“The request seemed last-minute, coming so soon before the test,” he notes. “As we previously discussed, it raised some eyebrows when the FCC announced that EAS participants are required to file Form Two by 11:59pm Eastern on the same day as the test itself, leaving less than 10 hours after the test for all EAS participants to file.”

There are also new details available on what the test itself will look and sound like, Cohen points out.

Quoting senior FEMA staff, the audio portion of the test, including attention signals, will last approximately 50 seconds.  In addition, FEMA was asked to delete a previously included statement in the text scroll—“No action is needed.  This is only a test”—to avoid creating a difference between the aural and visual presentations, which had the potential to generate confusion among those with hearing or vision issues, Cohen says.

The test will start when FEMA sends the alert message, which will be in both English and Spanish.