• Get involved.
    We want your input!
    Apply for Membership and join the conversations about everything related to broadcasting.

    After we receive your registration, a moderator will review it. After your registration is approved, you will be permitted to post.
    If you use a disposable or false email address, your registration will be rejected.

    After your membership is approved, please take a minute to tell us a little bit about yourself.
    https://www.radiodiscussions.com/forums/introduce-yourself.1088/

    Thanks in advance and have fun!
    RadioDiscussions Administrators

WXNY IDing past TOH

They're not saying "HD2" but rather "HD, too"? Maybe that's what they can claim as a defense to escape a hefty fine. Oh, wait. The FCC isn't fining anyone for TOH minutiae like this anymore, right?
Let's get serious about this for a moment. The Commission has basically two options: change the rules, or enforce the rules that are on the books. If there don't need to be legal ID's at the top of each hour, modify the rule. If there don't need to be legal ID's, period, eliminate the rule. If they believe the rule reflects a necessity, or is mandated by the Communications Act [as modified], then enforce the damn thing. Punish the offenders. Revoke the licenses of serial offenders, no matter how well-connected they may be. Because "option 3", IMO, is untenable: remain a laughing stock, whose word is ignorable and whose presence is superfluous.
 
If Z-100 ID's as "WHTZ New York", that can't be their legal ID. It's only legal when they ID as Newark. (And yes, "HD2" is not accurate for their ID, legal or not, unless they're simulcasting on HD1 and HD2, and then where's the HD1 ID?)
They are the only iHeart stations that say HD1. WKTU, WAXQ and WLTW never mention their HD1.
 
The Commission has basically two options: change the rules, or enforce the rules that are on the books. If there don't need to be legal ID's at the top of each hour, modify the rule.

They have more than two options. Keep in mind that the FCC is not a police force. They don't have people monitoring radio stations in every city, checking for rule violations. They depend on listeners filing complaints. This isn't something people are likely to go through the paperwork to complain about. Nobody has ever lost their license about a TOH ID. They're not going to change the rules about IDs. The current rule is sufficient: Do it at a natural break. That's what happened here.
 
They have more than two options. Keep in mind that the FCC is not a police force. They don't have people monitoring radio stations in every city, checking for rule violations. They depend on listeners filing complaints. This isn't something people are likely to go through the paperwork to complain about. They're not going to change the rules about IDs. The current rule is sufficient: Do it at a natural break. That's what happened here.
So is the language in the rules ambiguous or lacking when it comes to HD subchannels? The station that's putting HD2 (or is that "too") in its ID and not HD1 when the actual signal has only an HD1 and no HD2 -- is that a violation?

I guess that doesn't matter, because competing stations aren't going to snitch to the FCC about ID language because no other station in the market is being harmed by a niggling "gotcha" violation, whether it's on the books or not.
 
  • Like
Reactions: djl
They have more than two options. Keep in mind that the FCC is not a police force. They don't have people monitoring radio stations in every city, checking for rule violations. They depend on listeners filing complaints. This isn't something people are likely to go through the paperwork to complain about. Nobody has ever lost their license about a TOH ID. They're not going to change the rules about IDs. The current rule is sufficient: Do it at a natural break. That's what happened here.
A sweep of eight songs-in-a-row is no more "unbreakable" than a sweep of eight commercial spots. If a five second legal ID can be buried in between spots in a cluster at x:49, it can be sequenced in between two songs played closest to the top of the hour. So if the language of the law doesn't reference TOH anymore, why shouldn't the legal be buried at the bottom of the hour? That's also a "natural break". If it does reference TOH, and the station isn't in the middle of some twenty minute symphony or live opera or breaking news coverage that truly is uninterruptible, that ID could have been at/near the true TOH.

As for "...the FCC is not a police force. They don't have people monitoring radio stations in every city, checking for rule violations..." The FCC has a headquarters in Washington DC, a major market. They have field offices in or near a number of other major markets. They also have non-field employees, and probably interns, who can listen to a radio while performing other functions. Everyone has a desktop or laptop computer, which is capable of recording audio. (And if they can't figure it out, I'll be glad to show them.) So devote a month to monitoring stations in each of their local markets, logging and recording the legal IDs (and confirming that they truly are "legal"), and then, at the end of the month, issue violation notices to the offenders. In those warnings, state that future violations will result in fines and eventual revocations. Issue a press release.

Wanna make book on how long it will take for word to get around the industry, and how many minutes more before they clean up their acts? This stuff is not brain surgery, or even transmitter maintenance.

Nobody had a gun put to their head to acquire a broadcast license. Everybody who did, did it voluntarily, and attested to their intent to follow the laws and rules of the United States. So follow them, and enforce them. Put everyone on notice of the government's intent to go back to enforcing its own code, and weed out the bad actors. A lot of the other bad acting and "ignored" rules will fall into line once they show a renewed seriousness. Simple concept, even if it may not be trivial to achieve.
 
So is the language in the rules ambiguous or lacking when it comes to HD subchannels? The station that's putting HD2 (or is that "too") in its ID and not HD1 when the actual signal has only an HD1 and no HD2 -- is that a violation?

I guess that doesn't matter, because competing stations aren't going to snitch to the FCC about ID language because no other station in the market is being harmed by a niggling "gotcha" violation, whether it's on the books or not.
That's crap. We all speed because we know we can get away with it, because the bigger fool is speeding even faster, and that's the jerk the cops are going to target. Ever see what happens when there is a plainclothes officer in an unmarked car with a radar gun, and a bunch of patrol cars half a mile down the freeway ready to pounce? A few drivers get nailed, and everyone else suddenly rediscovers the speed limit. If the Commish starts to grow a pair once again, the natives will rediscover the rules of the road. And if the rules are an anachronism in today's world, modernize them. But enforce whatever's there and the violations will dry up, or the bad actors will get wrung out of the industry.
 
A sweep of eight songs-in-a-row is no more "unbreakable" than a sweep of eight commercial spots.
I don't know the context here. Do you?

The FCC has a headquarters in Washington DC, a major market. They have field offices in or near a number of other major markets. They also have non-field employees, and probably interns, who can listen to a radio while performing other functions.

Their budget gets cut all the time. They don't use interns to listen to the radio. Their employees are involved in lots of other things besides radio. In fact, radio is a very small part of their responsibilities. They have a procedure for violations, and I explained it in my previous post. If you have time on your hands, file some complaints with the FCC.

Put everyone on notice of the government's intent to go back to enforcing its own code, and weed out the bad actors.

You're not living in the real world. Next month, the congress is going to be fighting over the federal budget. They'll be looking for things to cut, and my bet is that the FCC will once again be on the chopping block. They aren't looking to spend more taxpayer money to enforce legal ID rules for radio stations. That's simply not a priority.
 
That's crap. We all speed because we know we can get away with it, because the bigger fool is speeding even faster, and that's the jerk the cops are going to target. Ever see what happens when there is a plainclothes officer in an unmarked car with a radar gun, and a bunch of patrol cars half a mile down the freeway ready to pounce? A few drivers get nailed, and everyone else suddenly rediscovers the speed limit. If the Commish starts to grow a pair once again, the natives will rediscover the rules of the road. And if the rules are an anachronism in today's world, modernize them. But enforce whatever's there and the violations will dry up, or the bad actors will get wrung out of the industry.
Bad actors in radio are the pirates, the over-powered translator operators, the stations that "forget" to power down until 10:00 on Friday night because the local high school football team is playing, not the TOH ID "outlaws." You're not going to get stations testing the FCC's tolerance in things that matter in any serious sense if you wink at an ID that comes two minutes too late.
 
A Natural Break in Programming is defined by the station and the FCC is fine with that. In fact, in Houston, an FCC Field Examiner stopped in and wanted us to do an EAS Test. He said we should wait until the next commercial break some 20 minutes later and he was okay with that. We interrupted the song and did it within seconds. The guy was shocked. My response was "Isn't the point to get the info on the air as quickly as possible in a real emergency? For us, that's seconds."
 
Exactly, but it told the FCC Field Examiner we took the FCC seriously and he got pretty friendly after that. He sat around with us, shot the breeze and had a cup of coffee for about half an hour. During his visit he saw one thing and told me how to correct it instead of writing us up.
 
At least a long time ago, when a station broke into programming including the middle of a song to do a news bulletin, there are listeners who like to be the first to get the news story and they will choose that station to listen to.

But interrupting a song to put on an EBS, oops I mean EAS, test would look like an obnoxious interruption to many folks.

Except some tests are sent only to a few "key" stations and other stations are supposed to monitor the key stations and "immediately" do the test to notify third level stations monitoring them and so on. If the fourth level station waits 20 minutes to get to a commercial break and then does the EAS test, then the fifth, sixth, etc. stations in the daisy chain don't get the message for a "long" time.

One automated station (an oldies station) I listen to regularly did not ID at all before some of their syndicated programs for several months. They had just neglected to program their short ID announcement at the top of the hour when the syndicated program was scheduled. Said syndicated program appeared to be locally loaded (would be an LP disk or a tape in ages past) as opposed to a stream (a network feed in ages past) requiring time synchronization with an external source.
 
Last edited:
At least a long time ago, when a station broke into programming including the middle of a song to do a news bulletin, there are listeners who like to be the first to get the news story and they will choose that station to listen to.

But interrupting a song to put on an EBS, oops I mean EAS, test would look like an obnoxious interruption to many folks.

Except some tests are sent only to a few "key" stations and other stations are supposed to monitor the key stations and "immediately" do the test to notify third level stations monitoring them and so on. If the fourth level station waits 20 minutes to get to a commercial break and then does the EAS test, then the fifth, sixth, etc. stations in the daisy chain don't get the message for a "long" time.

One automated station (an oldies station) I listen to regularly did not ID at all before some of their syndicated programs for several months. They had just neglected to program their short ID announcement at the top of the hour when the syndicated program was scheduled. Said syndicated program appeared to be locally loaded (would be an LP disk or a tape in ages past) as opposed to a stream (a network feed in ages past) requiring time synchronization with an external source.
There's no "fourth or fifth level."

There are seventy-some "PEP" (primary entry point) stations that are directly connected to FEMA for disseminating national emergency messages. Those messages are also distributed these days via alternate sources, including an Internet feed.

Every operational area (usually roughly equivalent to a single radio market) has one or two "LP1" stations (local primary) and one or two "LP2" stations. The LP1 stations are the ones where local and state emergency agencies originate notifications, and where NWS messages enter the system.

And everyone else in those markets ("participating" stations) is assigned to monitor two of the LP stations.

Nobody is assigned to monitor the participating stations.

So any message that enters the system goes through only one or two levels to reach any given station, and there are multiple paths so that even if it's delayed on one station, it will be picked up sooner from another.

Does that make sense?
 
50 years ago the requirement for station identification was within 2 minutes of the top AND bottom of the hour. That requirement is long gone. 73.1201(a)(2) states “hourly, as close to the hour as feasible, at a natural break in program offerings.” That offers a good deal of latitude on the part of the station.
The downsized FCC has bigger fish to fry.
It’s why I’m not holding my breath that they’ll cite WABC for continually mis-identifying their co-owned Suffolk County FM a station as “WLIR Hampton Bays”.
The callsign of that station on 107.1 is “WLIR-FM”.
The city of license is not Hampton Bays?
 
I don’t think the FCC cares about Legal IDs anymore, nor has the manpower to enforce rules surrounding identification. Even if the incidents are reported, I highly doubt the FCC will take any action at all.

One of the stations in Dallas has a hyphenated city of license and hasn’t been identifying the second city for over a year now. I also know of a station in Illinois that didn’t legal ID at all for over 10 years. That station eventually had their licensed cancelled, but it was due to other issues, including abandonment of the station.

Should there be an FCC rule requiring legal identification if it’s not enforced? Probably not. Is rewriting the rules a high priority for the FCC? Also, probably not.
 
Status
This thread has been closed due to inactivity. You can create a new thread to discuss this topic.


Back
Top Bottom