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KSCO(AM), Santa Cruz, CA Whoops

F

Frequency1

Zwerling Broadcasting System, LTD
2300 Portola Drive Santa Cruz, CA 95062
Re: Zweling Broadcasting System, LTD
KSCO(AM), Santa Cruz, CA
Fac. ID No.: 41594
Special Temporary Authority Dear Applicant:
This is in reference to the request filed September 7, 2022, on behalf of Zwerling Broadcasting System, LTD ("ZBS"). ZBS requests special temporary authority ("STA") to continue to operate station KSCO(AM) during nighttime hours with its daytime antenna system at reduced power. 1 In support of the request, ZBS states that the station has operated non-directionally at night with reduced power for more than thirty years. The station has been operating with a power of 1 kilowatt, which is 20% of its licensed nighttime power, and is requesting an STA to continue to operate with this reduced power facility. However, because the station is operating nondirectionally, this results in the station transmitting significantly more power in some directions than KSCO(AM) is authorized. ZBS further states that the reason for the request is that the station’s licensed directional mode does not cover a significant amount of the station’s primary service area, which includes many communities of Santa Cruz and Monterey Counties. Thus, the station is requesting an STA to continue to operate during nighttime hours with its daytime non-directional pattern and with its nighttime power reduced from 5 kilowatts to 1 kilowatt. According to its own statements KSCO(AM) has operated with unauthorized nighttime facilities for at least the last 25 years. Additionally, the station does not provide a justification for the need to operate with an alternate antenna system and reduced power during nighttime hours, beyond the desire to increase coverage in certain areas. Furthermore, the station does not provide any engineering studies to show that the proposed STA facility would protect other cochannel and first adjacent stations. Based on our interference studies the proposed 1 kilowatt non-directional nighttime operation is predicted to cause prohibited interference to multiple stations, including Class A station KRLD on 1080 kHz, licensed to Dallas, Texas. The need to protect KRLD appears to place the greatest limitation on KSCO(AM)’ ability for a nondirectional nighttime operation, and protection of KRLD(AM) would require KSCO(AM) to reduce power to 28 watts.

Accordingly, the KSCO(AM) request for STA to operate non-directionally at night at 1 kilowatt of power is DENIED. Station KSCO(AM) must terminate its unauthorized non-directional operation at night IMMEDIATELY and may either resume operating with its licensed directional nighttime facilities or file a 301 application to modify its nighttime operation.
 
According to a 2022 satellite image, the 3 towers are still there (3 are needed for night, 1 needed for day).

Paraphrased, they say that their licensed directional mode does not cover a significant amount of their primary service area, so for the last 30+ years, they've been using their own power output and pattern that will do so (contrary to what the FCC authorized).

How could anyone think this would be okay to say?
 
Red Plume said:
According to a 2022 satellite image, the 3 towers are still there (3 are needed for night, 1 needed for day).

Paraphrased, they say that their licensed directional mode does not cover a significant amount of their primary service area, so for the last 30+ years, they've been using their own power output and pattern that will do so (contrary to what the FCC authorized).

How could anyone think this would be okay to say?
Click to expand...
How does this not end up with a license forfeiture?
 
Here, daytimer 1510 AM has, on a few occasions (reportedly due to a faulty timer switch), no gone OTA at ~sundown and was reported almost immediately, I thought in the ~30 years there would have been at least 1 Gov/FCC inspection of the KSCO facility (or possibly a listener complaint about the other AMs on 1080 being interfered with at night by KSCO).


Kirk Bayne
 
kfbkfb said:
Here, daytimer 1510 AM has, on a few occasions (reportedly due to a faulty timer switch), no gone OTA at ~sundown and was reported almost immediately, I thought in the ~30 years there would have been at least 1 Gov/FCC inspection of the KSCO facility (or possibly a listener complaint about the other AMs on 1080 being interfered with at night by KSCO).


Kirk Bayne
Click to expand...
Here's the thing---the engineer was running a lower than authorized power, but non-directionally. So he may in fact have avoided causing interference with the other 1080s (given the noise floor the past few decades, who'd notice). BUT---you don't get to make that decision on your own. To do it for 30 years-----like I said, I have no idea how this doesn't end up in a license forfeiture.
 
kfbkfb said:
Here, daytimer 1510 AM has, on a few occasions (reportedly due to a faulty timer switch), no gone OTA at ~sundown and was reported almost immediately, I thought in the ~30 years there would have been at least 1 Gov/FCC inspection of the KSCO facility (or possibly a listener complaint about the other AMs on 1080 being interfered with at night by KSCO).
Click to expand...
I have not heard of a night-time FCC inspection in 50 years. And in recent decades, the FCC takes action when it gets a complaint. There are few daytime facility checks, and those are mostly about things like record keeping.

The era of the transmitter site inspection nearly disappeared when the FCC saw that today's equipment is very stable and reliable; you are more likely to get a citation for not having tower signs posted or locked gates at tower bases.

Look at 1080 at night on the maps here: https://worldradiohistory.com/Archive-Radio-Logbooks/Dataworld-A-Maps-1997.pdf and you will see that it is unlikely that any station on that channel cared about some interference in northern California and even less likely that a listener might object to it.
 
Maybe this is a wake up call for the FCC to verify that directional AM stations really are directional when they should be (possibly some sort of random spot checks of signal strength for day and night operation).


Kirk Bayne
 
kfbkfb said:
Maybe this is a wake up call for the FCC to verify that directional AM stations really are directional when they should be (possibly some sort of random spot checks of signal strength for day and night operation).
Click to expand...
That would be a multi-year project of multiple teams of engineers. Not going to happen.

AM is going to continue to see "thinning of the herd" as well as complex directionals going to low power non-DA operations. I think a lot of the incompetent operations will just fade away before the FCC every gets this act together.
 
So what decision was made by engineering or management to not have the directional array repaired in this case?

I'll concur with the masses, turn off the transmitter and return the license.
 
kwthom said:
So what decision was made by engineering or management to not have the directional array repaired in this case?
Click to expand...
My guess involves two scenarios and could be, also, a combination of both.

First, the licensed facility did not cover most of the market at night. Second, the directional system went out of adjustment and it's very expensive to do a major readjustment. So the licensee may have said, "cut the power back and run non-directional" and then failed to notify the FCC of an engineering emergency...which would have required a timetable for restoration of the licensed facility.
kwthom said:
I'll concur with the masses, turn off the transmitter and return the license.
Click to expand...
Or get a good DA engineer to adjust the pattern into compliance. Generally, local engineers or the station's contract engineer don't do this, particularly at the design level.
 
Maybe KSCO could - to coin a new term - become a morningtimer (only broadcast an omni signal on AM from 7AM to 9:10AM, transmitter off at other times [9:10 to include a top of the hour national newscast, local news and an automated reminder to tune to one of the FM translators]).


Kirk Bayne
 
kfbkfb said:
Maybe KSCO could - to coin a new term - become a morningtimer (only broadcast an omni signal on AM from 7AM to 9:10AM, transmitter off at other times [9:10 to include a top of the hour national newscast, local news and an automated reminder to tune to one of the FM translators]).
Click to expand...
Stations are required to run a minimum schedule during its licensed hours. Doing 2 morning hours would not meet the minimum for a fulltime licensed station.
 
It's fairly common these days for AM stations to give up a complicated nighttime directional tower array. That way it can still be on the air at full power in the daytime, when it is authorized to broadcast non-directonally, and run low power at night. Recently WSYB Rutland VT did it. It was authorized to run 5,000 watts days non-directional. But at night it needed a three-tower array to run 1,000 watts. So WSYB got permission to lose two towers. It went to a nighttime power of 25 watts. It has an FM translator, so that's what everyone is probably listening to anyway.

It is puzzling to me why KSCO admitted it did this for the last 30 years! If you want to go to lower power at night and lose your extra towers, the FCC likely will say yes. No need to admit your past sins.

With three FM translators, it has no need to run anything more than a few watts at night. But what Washington-based law firm or engineering firm allowed KSCO to admit it's been doing this without authorization, when the FCC never knew?
 
In at least one case, an AM daytimer is allowed to operate and program their FM translator(s) 24/7, since the FMs are allowed to operate 24/7 with the (controlling) AM on during only during the day, IMHO an AM station should be allowed to operate only during profitable hours (reading RD.com, it seems that time is in the morning).

It would likely require a rules change by the FCC, but, AFAIK, the FCC cares about keeping interference low by specifying technical parameters, if an AM station wants to be OTA for ~2hrs/day, I'd say let them.


Kirk Bayne
 
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