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                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554

In the Matter of                )
                                )
Galaxy American Communications, L.L.C.  )    File  No.  EB-02-TS-
176
d/b/a CableDirect               )
                                )
Operator of Cable Systems in the States of:  )
                                )
Colorado, Illinois, Indiana, Iowa, Kansas,   )
Missouri, Nebraska, Oklahoma, Texas, )
                                )
Request for Waiver of Section 11.11(a) of the     )    
Commission's Rules              )    
                                        
                              ORDER 

Adopted:  October 1, 2002               Released:    October   7, 
2002

By the Chief, Technical  and Public Safety Division,  Enforcement 
Bureau:

1.           In   this   Order,   we   grant   Galaxy    American 
  Communications, L.L.C.  d/b/a CableDirect     (``CableDirect'') 
  temporary,  36-month  waivers   of  Section  11.11(a)  of   the 
  Commission's  Rules   (``Rules'')  for  316  cable   television 
  systems   in  the   nine  above-captioned   states  listed   in 
  Attachment A.  Section 11.11(a) requires cable systems  serving 
  fewer than 5,000  subscribers from a headend to either  provide 
  national  level Emergency  Alert System  (``EAS'') messages  on 
  all programmed channels or install EAS equipment and provide  a 
  video interrupt and audio alert on all programmed channels  and 
  EAS  audio  and  video messages  on  at  least  one  programmed 
  channel by October 1, 2002.1

2.        The Cable Act of 1992  added new Section 624(g) to  the 
  Communications  Act  of 1934  (``Act''),  which  requires  that 
  cable  systems be  capable of  providing  EAS alerts  to  their 
  subscribers.2  In 1994, the Commission adopted rules  requiring 
  cable systems to participate in EAS.3  In 1997, the  Commission 
  amended the  EAS rules  to provide financial  relief for  small 
  cable systems.4  The Commission declined to exempt small  cable 
  systems  from the  EAS requirements,  concluding that  such  an 
  exemption would be  inconsistent with the statutory mandate  of 
  Section  624(g).5    However,  the   Commission  extended   the 
  deadline   for  cable   systems  serving   fewer  than   10,000 
  subscribers to  begin complying with the  EAS rules to  October 
  1, 2002,  and provided cable systems  serving fewer than  5,000 
  subscribers the option  of either providing national level  EAS 
  messages  on   all  programmed  channels   or  installing   EAS 
  equipment and  providing a video interrupt  and audio alert  on 
  all programmed channels and EAS audio and video messages on  at 
  least  one programmed  channel.6  In  addition, the  Commission 
  stated that  it would grant waivers of  the EAS rules to  small 
  cable  systems  on  a case-by-case  basis  upon  a  showing  of 
  financial  hardship.7   The Commission  indicated  that  waiver 
  requests must contain at least the following information:   (1) 
  justification for the waiver, with reference to the  particular 
  rule sections  for which  a waiver is  sought; (2)  information 
  about the financial status of the requesting entity, such as  a 
  balance sheet and  income statement for the two previous  years 
  (audited, if possible);  (3) the number of other entities  that 
  serve the  requesting entity's coverage area  and that have  or 
  are expected to  install EAS equipment; and (4) the  likelihood 
  (such  as proximity  or frequency)  of hazardous  risks to  the 
  requesting entity's audience.8

3.        On  May  8,  2002,  CableDirect  filed  a  request  for 
  temporary, 36-month waivers  of Section 11.11(a) for 316  small 
  rural  cable systems  in Attachment  A  in the  nine  captioned 
  states.  In support  of the waiver request, CableDirect  states 
  that  the  316 cable  systems  each  serve between  1  and  447 
  subscribers. Based  on price quotes  provided by EAS  equipment 
  manufacturers,  CableDirect estimates  that  it would  cost  at 
  least  $10,000  to  install EAS  equipment  at  each  of  these 
  systems for  a total cost  of $3,160,000.  CableDirect  asserts 
  that this cost will impose a substantial financial hardship  on 
  it and provides its  financial statements for 2000 and 2001  in 
  support of  this assertion.  In  addition, CableDirect  submits 
  that  its subscribers  will continue  to have  ready access  to 
  national  EAS information  from  other sources,  including  its 
  cable  systems.  In  this regard,  CableDirect notes  that  its 
  subscribers currently have  access to national EAS messages  on 
  approximately   57   percent  of   all   programmed   channels.  
  CableDirect also asserts that its subscribers will have  access 
  to EAS information through over-the-air reception of  broadcast 
  television and radio stations. 

4.        Based upon our review of  the financial data and  other 
  information  submitted   by  CableDirect,   we  conclude   that 
  temporary, 36-month  waivers of  Section 11.11(a)  for the  316 
  cable systems in Attachment  A in the nine captioned states  is 
  warranted.9   In  particular,   we  find  that  the   estimated 
  $3,160,000 cost to  install EAS equipment for these very  small 
  systems could impose a financial hardship on CableDirect.

5.        We note that  the Commission recently  amended the  EAS 
  rules  to  permit  cable  systems  serving  fewer  than   5,000 
  subscribers  to   install  FCC-certified  decoder-only   units, 
  rather  than both  encoders  and  decoders, if  such  a  device 
  becomes  available.10    Based  on   comments  from   equipment 
  manufacturers, we  anticipate that such  a decoder-only  system 
  could  result  in  significant  cost  savings  to  small  cable 
  systems.11  

6.        Accordingly, IT IS ORDERED  that, pursuant to  Sections 
  0.111,  0.204(b) and  0.311 of  the Rules,12   Galaxy  American 
  Communications, L.L. C.  d/b/a CableDirect IS GRANTED a  waiver 
  of Section 11.11(a) of the Rules until October 1, 2005 for  the 
  316 cable television systems listed in Attachment A. 

7.        IT   IS   FURTHER   ORDERED   that   Galaxy    American 
  Communications, L.L. C. d/b/a CableDirect place a copy of  this 
  waiver in its systems files.

8.        IT IS FURTHER ORDERED that  a copy of this Order  shall 
  be sent by  Certified Mail Return Receipt Requested to  counsel 
  for Galaxy American Communications, L.L. C. d/b/a  CableDirect, 
  Christopher  C. Cinnamon,  Esq.,  Cinnamon Mueller,  307  North 
  Michigan Avenue, Suite 1020, Chicago, Illinois 60601.

                         FEDERAL COMMUNICATIONS COMMISSION

                         


                         Joseph P. Casey
                         Chief, Technical and Public Safety 
Division
                         Enforcement Bureau
                                                Attachment A

   Galaxy American Communications, L.L.C. d/b/a CableDirect

   Cable Systems:                       Temporary Waiver Granted 
Until:    

   Colorado
   Aguilar, Colorado                         October 1, 2005
   Boone, Colorado                      October 1, 2005
   Cheraw, Colorado                     October 1, 2005
   Crowley, Colorado                         October 1, 2005
   Olney Springs, Colorado                   October 1, 2005
   Pueblo/Avondale, Colorado            October 1, 2005
   Sugar City, Colorado                 October 1, 2005

   Illinois
   Allendale, Illinois                       October 1, 2005
   Alsey, Illinois                      October 1, 2005
   Arrowsmith, Illinois                 October 1, 2005
   Baldwin, Illinois                         October 1, 2005
   Beaverville, Illinois                October 1, 2005
   Beecher City, Illinois                    October 1, 2005
   Belle Rive, Illinois                      October 1, 2005
   Bellmont, Illinois                        October 1, 2005
   Bismarck, Illinois                        October 1, 2005
   Bluford, Illinois                         October 1, 2005
   Bonfield, Illinois                        October 1, 2005
   Browns, Illinois                     October 1, 2005
   Campbell Hill, Illinois                   October 1, 2005
   Carlock, Illinois                         October 1, 2005
   Chestnut, Illinois                        October 1, 2005
   Cisco, Illinois                      October 1, 2005
   Cowden, Illinois                     October 1, 2005
   Cypress, Illinois                         October 1, 2005
   Dahlgren, Illinois                        October 1, 2005
   Dongola, Illinois                         October 1, 2005
   Donovan, Illinois                         October 1, 2005
   Dubois, Illinois                     October 1, 2005
   East Carondelet, Illinois                 October 1, 2005
   Eldred, Illinois                     October 1, 2005
   Ellis Grove, Illinois                October 1, 2005
   Flat Rock, Illinois                       October 1, 2005
   Grand Chain, Illinois                October 1, 2005
   Grand Detour, Illinois                    October 1, 2005
   Gulfport, Illinois                        October 1, 2005
   Henning, Illinois                         October 1, 2005
   Hoyleton, Illinois                        October 1, 2005   Cable Systems:                       Temporary Waiver Granted 
Until:    

   Ina, Illinois                        October 1, 2005
   Iroquois, Illinois                        October 1, 2005
   Irvington, Illinois                       October 1, 2005
   Joppa, Illinois                      October 1, 2005
   Joy, Illinois                        October 1, 2005
   Karnak, Illinois                     October 1, 2005
   Keensburg, Illinois                       October 1, 2005
   Keithsburg, Illinois                      October 1, 2005
   Kirkwood, Illinois                        October 1, 2005
   Lake Camelot, Illinois                    October 1, 2005
   Laplace, Illinois                         October 1, 2005
   Lee, Illinois                        October 1, 2005
   Logan (Hanaford), Illinois                October 1, 2005
   Long Point, Illinois                      October 1, 2005
   Magnolia, Illinois                        October 1, 2005
   Manchester, Illinois                 October 1, 2005
   Martinton, Illinois                       October 1, 2005
   Mason, Illinois                      October 1, 2005
   Media, Illinois                      October 1, 2005
   Mulberry Grove, Illinois                  October 1, 2005
   New Boston, Illinois                 October 1, 2005
   New Burnside, Illinois                    October 1, 2005
   New Minden/Nashville, Illinois            October 1, 2005
   Oakrun (Metamora), Illinois               October 1, 2005
   Ohio, Illinois                       October 1, 2005
   Olmsted, Illinois                         October 1, 2005
   Paw Paw, Illinois                         October 1, 2005
   Penfield, Illinois                        October 1, 2005
   Pinewood Park, Illinois                   October 1, 2005
   Pocohantas, Illinois                 October 1, 2005
   Redmon, Illinois                     October 1, 2005
   Royal, Illinois                      October 1, 2005
   Sadorus, Illinois                         October 1, 2005
   Seaton, Illinois                     October 1, 2005
   Steward, Illinois                         October 1, 2005
   Stonefort, Illinois                       October 1, 2005
   Tamaroa, Illinois                         October 1, 2005
   Thawville, Illinois                       October 1, 2005
   Thompsonville, Illinois                   October 1, 2005
   Troy Grove, Illinois                 October 1, 2005
   W. Pierrone/E. Pierrone, Illinois              October 1, 2005
   Waltonville, Illinois                October 1, 2005
   West Salem, Illinois                 October 1, 2005
   West Union, Illinois                 October 1, 2005
   White Heath/Monticello, Illinois               October 1, 2005   Cable Systems:                       Temporary Waiver Granted 
Until:    

   Indiana
   Andrews, Indiana                     October 1, 2005
   Arlington/Rush Co., Indiana               October 1, 2005
   Ashley, Indiana                      October 1, 2005
   Big Long Lake/Big Lake, Indiana           October 1, 2005
   Boswell, Indiana                     October 1, 2005
   Bretzville/Stant-Marks, Indiana           October 1, 2005
   Cataract Lake/Owen Co., Indiana           October 1, 2005
   Chrisney, Indiana                         October 1, 2005
   Claypool, Indiana                         October 1, 2005
   Clear Lake, Indiana                  October 1, 2005
   Cloverdale, Indiana                  October 1, 2005
   Crane, Indiana                       October 1, 2005
   Dana, Indiana                        October 1, 2005
   Darlington, Indiana                       October 1, 2005
   Dubois, Indiana                      October 1, 2005
   Fish Lake/Lagrange Co./Royer, Indiana          October 1, 2005
   Frankton, Indiana                         October 1, 2005
   Freetown/Jackson Co., Indiana             October 1, 2005
   Gaston, Indiana                      October 1, 2005
   Gentryville, Indiana                 October 1, 2005
   Golden Lake, Indiana                 October 1, 2005
   Hillsboro, Indiana                        October 1, 2005
   Hoagland/Poe/Mill Rd, Indiana             October 1, 2005
   Holland, Indiana                     October 1, 2005
   Jamestown, Indiana                   October 1, 2005
   Kimmell, Indiana                     October 1, 2005
   Kingman, Indiana                     October 1, 2005
   Knapp Lake, Indiana                  October 1, 2005
   Ladoga, Indiana                      October 1, 2005
   Lafontaine, Indiana                  October 1, 2005
   Lagro, Indiana                       October 1, 2005
   Lapel, Indiana                       October 1, 2005
   Liberty Mills, Indiana                    October 1, 2005
   Macy, Indiana                        October 1, 2005
   Manilla/Homer, Indiana                    October 1, 2005
   Markle, Indiana                      October 1, 2005
   Mentone, Indiana                     October 1, 2005
   Milroy, Indiana                      October 1, 2005
   Mongo/Lagrange Co., Indiana               October 1, 2005
   Monterey, Indiana                         October 1, 2005
   Montezuma, Indiana                   October 1, 2005
   Morristown, Indiana                  October 1, 2005
   New Market, Indiana                  October 1, 2005
   Newport, Indiana                     October 1, 2005

   Cable Systems:                       Temporary Waiver Granted 
Until:    

   Oliver Lake/Wolcotville, Indiana               October 1, 2005
   Orland, Indiana                      October 1, 2005
   Otter Lake, Indiana                       October 1, 2005
   Otwell, Indiana                      October 1, 2005
   Owensberg, Indiana                   October 1, 2005
   Oxford, Indiana                      October 1, 2005
   Perrysville, Indiana                      October 1, 2005
   Pretty Lake/Big Long Lake, Indiana        October 1, 2005
   Roann, Indiana                       October 1, 2005
   Royal Center, Indiana                October 1, 2005
   Russellville, Indiana                October 1, 2005
   Sheridan, Indiana                         October 1, 2005
   Shipshewana, Indiana                 October 1, 2005
   Somerset, Indiana                         October 1, 2005
   Spurgeon, Indiana                         October 1, 2005
   St. Paul, Indiana                         October 1, 2005
   Summitville, Indiana                 October 1, 2005
   Topeka, Indiana                      October 1, 2005
   Twin Lake/Howe, Indiana                   October 1, 2005
   Urbana, Indiana                      October 1, 2005
   Van Buren, Indiana                   October 1, 2005
   Walton, Indiana                      October 1, 2005
   Waveland, Indiana                         October 1, 2005
   Waynetown, Indiana                   October 1, 2005
   West Lebanon, Indiana                October 1, 2005
   West Point, Indiana                  October 1, 2005
   Whitestown, Indiana                  October 1, 2005
   Worthington, Indiana                 October 1, 2005
   Young America, Indiana                    October 1, 2005
   Zanesville, Indiana                       October 1, 2005

   Iowa
   Adiar, Iowa                     October 1, 2005
   Afton, Iowa                     October 1, 2005
   Alexander, Iowa                      October 1, 2005
   Allerton, Iowa                       October 1, 2005
   Braddyville, Iowa                         October 1, 2005
   Bridgewater, Iowa                         October 1, 2005
   Chester, Iowa                        October 1, 2005
   Cincinnati, Iowa                     October 1, 2005
   Coin, Iowa                           October 1, 2005
   College Springs, Iowa                October 1, 2005
   Conesville, Iowa                     October 1, 2005
   Crawfordsville, Iowa                 October 1, 2005
   Cable Systems:                       Temporary Waiver Granted 
Until:    

   Cumberland, Iowa                     October 1, 2005
   Delta, Iowa                     October 1, 2005
   Denmark/Lee Co., Iowa                October 1, 2005
   Donnellson, Iowa                     October 1, 2005
   Drakesville, Iowa                         October 1, 2005
   Fontanelle, Iowa                     October 1, 2005
   Garden Grove, Iowa                   October 1, 2005
   Grandview, Iowa                      October 1, 2005
   Hastings, Iowa                       October 1, 2005
   Henderson, Iowa                      October 1, 2005
   Holland, Iowa                        October 1, 2005
   Humeston, Iowa                       October 1, 2005
   Keswick, Iowa                        October 1, 2005
   Letts, Iowa                          October 1, 2005
   Lincoln, Iowa                        October 1, 2005
   Lineville, Iowa                      October 1, 2005
   M&W MHP/Muscatine/Ripley, Iowa       October 1, 2005
   Massena, Iowa                        October 1, 2005
   Moravia, Iowa                        October 1, 2005
   Moulton, Iowa                        October 1, 2005
   Mystic, Iowa                         October 1, 2005
   Oakville, Iowa                       October 1, 2005
   Orient, Iowa                         October 1, 2005
   Pacific Junction, Iowa                    October 1, 2005
   Prescott, Iowa                       October 1, 2005
   Pulaski, Iowa                        October 1, 2005
   Rowan, Iowa                     October 1, 2005
   Russell, Iowa                        October 1, 2005
   Salem, Iowa                     October 1, 2005
   Seymour, Iowa                        October 1, 2005
   Shambaugh, Iowa                      October 1, 2005
   Winfield, Iowa                       October 1, 2005          
   Wiota, Iowa                     October 1, 2005

   Kansas
   Bentley, Kansas                      October 1, 2005
   Burns, Kansas                        October 1, 2005
   Haddam, Kansas                       October 1, 2005
   La Harpe, Kansas                     October 1, 2005
   Mahaska, Kansas                      October 1, 2005
   Marquette, Kansas                         October 1, 2005
   Munden, Kansas                       October 1, 2005
   Narka, Kansas                        October 1, 2005
   Wisley, Kansas                       October 1, 2005   Cable Systems:                            Temporary Waiver 
   Granted Until:   

   Missouri
   Adrian, Missouri                     October 1, 2005
   Barnard, Missouri                         October 1, 2005
   Breckenridge, Missouri                    October 1, 2005
   Buffalo, Missouri                         October 1, 2005
   Burlington Junction, Missouri             October 1, 2005
   Cainsville, Missouri                 October 1, 2005
   Calhoun, Missouri                         October 1, 2005
   Canton, Missouri                     October 1, 2005
   Center, Missouri                     October 1, 2005
   Clearmont, Missouri                  October 1, 2005
   Cole Camp, Missouri                  October 1, 2005
   Creighton, Missouri                  October 1, 2005
   Crocker, Missouri                         October 1, 2005
   Deep Water, Missouri                 October 1, 2005
   Downing, Missouri                         October 1, 2005
   Eagleville, Missouri                 October 1, 2005
   Elmo, Missouri                       October 1, 2005
   Frankford, Missouri                  October 1, 2005
   Franklin, Missouri                        October 1, 2005
   Freeburg, Missouri                        October 1, 2005
   Garden City, Missouri                October 1, 2005
   Gilman City, Missouri                October 1, 2005
   Gorin, Missouri                      October 1, 2005
   Grant City, Missouri                 October 1, 2005
   Green Ridge, Missouri                October 1, 2005
   Hardin, Missouri                     October 1, 2005
   Holt, Missouri                       October 1, 2005
   Hopkins, Missouri                         October 1, 2005
   Iberia, Missouri                     October 1, 2005
   Johnson Co., Missouri                October 1, 2005
   Keytesville, Missouri                October 1, 2005
   King City, Missouri                  October 1, 2005
   Labelle, Missouri                         October 1, 2005
   Lamonte, Missouri                         October 1, 2005
   Lancaster, Missouri                  October 1, 2005
   Laredo, Missouri                     October 1, 2005
   Lewistown, Missouri                  October 1, 2005
   Lincoln, Missouri                         October 1, 2005
   Meadville, Missouri                  October 1, 2005
   Montrose, Missouri                   October 1, 2005
   Mound City, Missouri                 October 1, 2005
   New Hampton, Missouri                October 1, 2005
   New London, Missouri                 October 1, 2005
   Orrick, Missouri                     October 1, 2005
   Polo, Missouri                       October 1, 2005   Cable Systems:                       Temporary Waiver Granted 
Until:    

   Purdin, Missouri                     October 1, 2005
   Ridgeway, Missouri                   October 1, 2005
   Russelville, Missouri                October 1, 2005
   Spickard, Missouri                        October 1, 2005
   Stanberry, Missouri                  October 1, 2005
   Stewartsville, Missouri                   October 1, 2005
   Stover, Missouri                     October 1, 2005
   Taos, Missouri                       October 1, 2005
   Urich, Missouri                      October 1, 2005
   Vienna, Missouri                     October 1, 2005
   Wayland, Missouri                         October 1, 2005
   Westphalia, Missouri                 October 1, 2005
   Wyaconda, Missouri                   October 1, 2005

   Nebraska
   Cedar Creek, Nebraska                     October 1, 2005
   Dubois, Nebraska                     October 1, 2005
   Endicott, Nebraska                        October 1, 2005
   Lake Wa-Con-Da, Nebraska             October 1, 2005
   Otoe, Nebraska                       October 1, 2005
   Prague, Nebraska                          October 1, 2005
   Steinauer, Nebraska                  October 1, 2005
   Tobias, Nebraska                     October 1, 2005
   Union, Nebraska                      October 1, 2005
   Weston, Nebraska                     October 1, 2005

   Ohio
   Scott, Ohio                          October 1, 2005

   Oklahoma 
   Aline, Oklahoma                      October 1, 2005
   Butler, Oklahoma                     October 1, 2005
   Canton, Oklahoma                     October 1, 2005
   Carter, Oklahoma                     October 1, 2005
   Chattanooga, Oklahoma                     October 1, 2005
   Cleo Springs, Oklahoma                    October 1, 2005
   Davidson, Oklahoma                   October 1, 2005
   Deer Creek, Oklahoma                 October 1, 2005
   Duke, Oklahoma                       October 1, 2005
   Eldorado, Oklahoma                   October 1, 2005
   Fort Cobb, Oklahoma                  October 1, 2005
   Fort Supply, Oklahoma                October 1, 2005
   Garber, Oklahoma                     October 1, 2005
   Geronimo, Oklahoma                   October 1, 2005
   Gotebo, Oklahoma                     October 1, 2005
   Gracemont, Oklahoma                  October 1, 2005   Cable Systems:                       Temporary Waiver Granted 
Until:    

   Granite, Oklahoma                         October 1, 2005
   Lamont, Oklahoma                     October 1, 2005
   Lone Wolf, Oklahoma                  October 1, 2005
   Martha, Oklahoma                     October 1, 2005
   Medford, Oklahoma                    October 1, 2005
   Meno, Oklahoma                       October 1, 2005
   Ninnekah, Oklahoma                   October 1, 2005
   Olustee, Oklahoma                         October 1, 2005
   Red Rock, Oklahoma                   October 1, 2005
   Ripley, Oklahoma                     October 1, 2005
   Rocky, Oklahoma                      October 1, 2005
   Sentinel, Oklahoma                   October 1, 2005
   Synder, Oklahoma                     October 1, 2005
   Tipton, Oklahoma                     October 1, 2005
   Verden, Oklahoma                     October 1, 2005

   Texas 
   Mission/Bentsen Grove, Texas              October 1, 2005
   Pleasant Valley, Texas                    October 1, 2005
   Progreso, Texas                      October 1, 2005
   San Carlos, Texas                         October 1, 2005
   Sebastian, Texas                     October 1, 2005
_________________________

  1 47 C.F.R.  11.11(a).

  2 Cable Television  Consumer Protection and Competition Act  of 
1992, Pub. L. No. 102-385,  16(b), 106 Stat. 1460, 1490  (1992).  
Section 624(g) provides that  ``each cable operator shall  comply 
with such standards as the  Commission shall prescribe to  ensure 
that viewers of video programming  on cable systems are  afforded 
the same emergency  information as is  afforded by the  emergency 
broadcasting system pursuant to Commission regulations ....''  47 
U.S.C.  544(g).  

  3 Amendment  of Part 73, Subpart  G, of the Commission's  Rules 
Regarding the Emergency  Broadcast System, Report  and Order  and 
Further Notice of Proposed Rule Making, FO Docket Nos. 91-171/91-
301, 10  FCC  Rcd  1786  (1994)  (``First  Report  and  Order''), 
reconsideration granted in part, denied in part, 10 FCC Rcd 11494 
(1995).

  4 Amendment  of Part 73, Subpart  G, of the Commission's  Rules 
Regarding the  Emergency  Broadcast  System,  Second  Report  and 
Order, FO  Docket Nos.  91-171/91-301, 12  FCC Rcd  15503  (1997) 
(``Second Report and Order'').

  5 Id. at 15512-13.

  6 Id. at 15516-15518.

  7 Id. at 15513.

  8 Id. at 15513, n. 59.

  9 The waivers will extend 36 months from October 1, 2002  until 
October 1, 2005.  CableDirect also specifically requested  waiver 
of the testing and monitoring  requirements of the EAS rules  for 
these 316 systems.  We clarify  that the waivers we are  granting 
also encompass the EAS testing and monitoring requirements.  

  10 Amendment  of Part  11 of the  Commission's Rules  Regarding 
the Emergency Alert System,  EB Docket 01-66, FCC  02-64 at   71 
(released February 26, 2002).

  11 One manufacturer  estimated that an EAS decoder-only  system 
can reduce the cost by 64% over what a cable operator would spend 
for an encoder/decoder unit.  Id. at  70.

  12 47 C.F.R.  0.111, 0.204(b) and 0.311.