Many of the most infractions that provoke FCC warnings and fines aren’t technical. Often they involve insufficient paperwork.
The dreaded notice of violation. No chief engineer wants to receive one, much less the fines that can roll in if the violation isn’t properly addressed.
Hence, engineers and operators attending this week’s 2006 SBE Broadcast & Technology Expo, held near Syracuse, N.Y., sat through hours of workshops on compliance. The grand finale, led by Terrence Baun, president of Criterion Broadcast Services, ranked the top 10 FCC violations and reviewed how to avoid them.
As part of the FCC’s Alternative Inspections program, Baun has conducted more than 800 TV and radio station inspections during the past decade. Here’s his hit list, ranked in descending order, with the most frequently seen violation first.
1. Failure to name a Designated Chief Operator and post the designation, in writing, where an inspector can see it. The DCO must review and sign the station’s log every week, without fail, and an alternative DCO must be appointed to officially take charge while the chief operator is on vacation or away for any reason.
2. Failure of a licensee to maintain a complete log. A log is a document that represents every day that a station is on the air. It notes any improper operations, why they happened and how they were corrected. Emergency Alert System activities must be noted and EAS receipts stapled to the log page. Tower lights must be observed every 24 hours if the station lacks an automatic tower lighting alarm system. It’s best to note each day that the lights have been observed and to record any failures.
3. Confusion over attended/unattended operations. Unattended operations are legal, but must be noted as such in the log. Operators must be able to turn off a transmitter within three hours if ordered to do so by the FCC, so an engineer must be able to drive to the location in that time if necessary. It isn’t necessary to have remote control equipment as long as the DCO can certify in the log that a remote transmitter is stable enough to maintain legal operation without remote control.
4. Failure to provide the most recent power calibration to the FCC. The most recent calibration may be several years old, as long as the transmitter has been operating well. Frequency and modulation monitors are not required, but they are helpful in demonstrating to the FCC that a station is in compliance.
5. Discrepancies between the ASR and the tower. The ASR is an FCC document describing the location, lighting and paint requirements of a tower. The tower has to be as described. ASRs don’t transfer to new owners when a station is sold. The seller must go into the FCC database and transfer ownership in order for the new owner to access the file. This can be done online and copies of a station’s ASR can be accessed from the FCC online and printed out.
6. EPM measurements are unavailable. If a station adds a new transmitter, antennas, exciters or subcarriers it can change occupied bandwidth, so bandwidth measurements must be done following changes like these.
7. Problems with the public file. A station’s engineer must maintain complete license renewal cards, ownership transfers and records of any special authorizations from the FCC. There must be a separate file for every station under license. Baun recommends keeping a file for each digital channel, although the law is currently unclear about whether this is required. He recommends that stations consult their attorneys if they have questions about digital channel files.
8. Transmitter power issues. An incorrect antenna or failure to switch power patterns as required is a no-no. TPO calculations must be noted.
9. Safety related issues such as a deteriorating tower fence. These can provoke an immediate fine.
10. EAS issues, including failure to send and receive EAS tests and activations without noting it in the log. The government is increasingly interested in the Emergency Alert System. Stations must have an EAS handbook and EAS must be in full auto mode while a station is operating unattended.