By Roy Pressman
When deregulation became reality, it seemed like the FCC was finally going to let broadcasters self-regulate the broadcast business. Many requirements were changed and -or- eliminated, but the burden of how to stay legal became the broadcaster's responsibility. The FCC demonstrated that they would come down hard on violators of the remaining regulations.
How can you make sure that your facility is legal?
First step; obtain one of the many FCC inspection checklists that are available such as the NAB's "The Radio Broadcasters' Inspection Checklist", (L-9304). Even the FCC field offices have been sending out checklists. Go through the checklist with your engineer and focus on areas that could leave you open for infractions/large fines. The FCC wants you to be prepared for an inspection. This is why they publishes an inspection checklist which details exactly what they will ask for when and if they visit you, so take some time and do your homework.
Let's take a quick walk through your station's air studio and look at a few areas that can help prevent an expensive FCC fine.
Monday Morning Studio Stroll-
Certain documents must be posted in the air studio (or control point). These documents don't have to be individually framed but must be kept in an area in the studio that is accessible and visible. A neat idea is to remove the front and back cover from a loose leaf binder, leaving the three ring binder assembly. Attach the assembly to a piece of wood with some screws and mount the wood/binder in the air studio. Place all necessary documents in clear plastic sleeves and put them in the binder.
What needs to be kept in the air studio?
Here's what to look for:
1. Your station license
2. Construction permits (if any)
3. Renewals (Usually in postcard form)
4. STA's (Special Temporary Authority)
5. Auxiliary transmitter/antenna licenses
6. All transmitter operator's licenses
All of your on-air personalities must have licenses posted in your air studio. There should be no exceptions to this rule. When new personalities are hired, make sure they have a valid license.(Restricted Radiotelephone Operator's Permit or other commercial radio license that does not preclude operation of a broadcast facility). Obtain several FCC form 753's from your local field office. Requireoperators without a license fill out and sign and mail in Form 753 to the FCC. Once this form is properly filled out, it allows an operator to temporarily operate a broadcast station until a permanent license is received from the FCC. (The current fee for the Restricted Radiotelphone Operators Permit is $45.00)
7. Written designation of Chief Operator-
It wasn't long ago when stations were required to have a Chief Engineer or contract engineer with an FCC First Class license. When this requirement was dropped, the "Chief Operator" designation was the replacement. The Chief Operator must hold at least a Restricted Radio Telephone Operators License. He or she essentially performs the duties of the "Chief Engineer" without the requirement of holding a First Class/General Class Commercial license. The "designation of chief operator" is nothing more than a short statement signed by the station general manager that names a particular person as the Chief Operator of your station. It must be posted in the air studio. If you are using a contract engineer, there should be a written contract available on request by FCC personnel.
8. Transmitter Log -
Although you are not required to take transmitter readings every three hours, you must have some way to insure that your station is within legal power limits. Require your on-air people to log transmitter readings every three hours. Have your engineer/Chief Operator post a chart identifying legal transmitter parameters. The chief operator should review and sign the transmitter logs on a daily basis.
Required log entries:
A.) Adjustment of any technical operating parameters and further description if adjustment was to correct an out-of-tolerance situation. Description of any repairs to transmitter system or antenna.
B.) Tower lights - Out or malfunctioning/tower light repairs-replacements.(Make sure the time and date are logged). Although no longer required by the FCC, check your tower lights at least once every 24 hours, preferably in the evening when night falls.
C.) Date and time of each EBS test that is sent or received.
You may also be required to log additional information. Check your station license to see if there are any special conditions required by the FCC.
9. EBS Checklist and Authenticator Word List - Check the date on your EBS checklist. If you need to update your EBS materials, contact the FCC at 202-632-3906. Put all EBS materials in a clearly marked folder and post them next to your license binder.
10. Station Technical Procedure Manual - Although not required, there should be a reference manual in the studio containing the following topics:
1. How to take transmitter readings
2. How to turn the transmitter on and off
3. How to raise and lower the power
4. How to determine if the station's power output is within legal limits.(There should be an accompanying chart)
5. What to do if the station is not within legal power limits
6. Emergency procedures: How to change-over to your backup transmitter (provided you have one!)
7. How to transmit an EBS test
8. How to log EBS tests (Both received and transmitted)
9. Telephone number list including all main and standby engineers, general manager and program director
10. What to do if the tower lights malfunction
Set up a meeting with your air staff and review all materials in your "Technical Procedure Manual". The FCC requires you to make sure that your on-air staff is familiar with all technical operational procedures, so it's wise to thoroughly go-over all materials contained in your manual.
Just be prepared!
Be prepared for an inspection. Obtain an inspection checklist, and set up a mach inspection at your facility. Discuss all applicable FCC rules and regulations with your engineer and legal council. Don't procrastionate, fix problem areas mediately. You have the ability to protect yourself from violations that will result in steep fines. It's simple, just be prepared!