Just curious. You legal types can set me straight here. Let's say we have two stations, an AM and an FM which share the same call letters. For legal ID purposes, is the FM required to include the term "FM" in it's hourly "call letter-city of license" verbage? (47 CFR, Part2, Subpart D)
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But is it legit?
- Thread starter robgrayson
- Start date
> they're still supposed to be at the top of the hour too...
That's not exactly true. From the Rules:
"Broadcast station identification announcements shall be made... as close to the hour as feasible, at a natural break in program offerings." 47 CFR § 73.1201(a)(2).
So, inside that :50 break is just fine. Essentially, one must ID as close to TOH as convenient.
DE
That's not exactly true. From the Rules:
"Broadcast station identification announcements shall be made... as close to the hour as feasible, at a natural break in program offerings." 47 CFR § 73.1201(a)(2).
So, inside that :50 break is just fine. Essentially, one must ID as close to TOH as convenient.
DE
DeadElvis said:
The FCC has actually fined stations for ID'ing less than 10 minutes to the top of the hour saying a break in songs was a feasible break in programming and that a break closer to the top of the hour should have been used. I remember being told some of those ID's were only three minutes from the top of the hour. So, I'm not sure burying the ID in the :50 break has always been considered "as close to the hour as feasible." However, those fines were from a number of years ago, and they'd probably be more likely to argue that and win today. I doubt the FCC even cares enough to inquire anymore, especially with stations as automated as they are now.
> Between songs IS a natural break in programming
Really? 'Ya sure?
A couple of things: I made a quick run through FCC caselaw (real quick, really), and found little directly on-point. There was a case where time near TOH was mentioned, but the real issue was more form of the ID, not placement, so I find the case less-than-useful.
If there is a case on-point, I would be interested in reading same, and will be happy to amend my comments accordingly.
That being said, an attorney (can't trust a one of 'em) would have a Field Day (this weekend, btw) with a Notice of Apparent Liability For Forfeiture on this issue. A lawyer's argument would hang, I suspect, on the language in the Rule itself... what is a "natural break in program offerings?" Just because the song is over, a lawyer might claim, we do not have a "break." There is a natural progression in programming elements that might be impinged upon with a stop for ID. This is a question of aesthetics that is beyond the scope of traditional FCC authority. Further, the language in the Rule is simply unclear. This is what Constitutional lawyers call, "Void for Vagueness."
I'll ID at :40, if I want. 'Can't do a darn thing about it.
'Course, I'm just a silly disk jockey.
DE
Really? 'Ya sure?
A couple of things: I made a quick run through FCC caselaw (real quick, really), and found little directly on-point. There was a case where time near TOH was mentioned, but the real issue was more form of the ID, not placement, so I find the case less-than-useful.
If there is a case on-point, I would be interested in reading same, and will be happy to amend my comments accordingly.
That being said, an attorney (can't trust a one of 'em) would have a Field Day (this weekend, btw) with a Notice of Apparent Liability For Forfeiture on this issue. A lawyer's argument would hang, I suspect, on the language in the Rule itself... what is a "natural break in program offerings?" Just because the song is over, a lawyer might claim, we do not have a "break." There is a natural progression in programming elements that might be impinged upon with a stop for ID. This is a question of aesthetics that is beyond the scope of traditional FCC authority. Further, the language in the Rule is simply unclear. This is what Constitutional lawyers call, "Void for Vagueness."
I'll ID at :40, if I want. 'Can't do a darn thing about it.
'Course, I'm just a silly disk jockey.
DE
Yep, I'm sure.
If I'm legally sure...well, as you say that's pretty vague.
But in the old days, another song meant you had to push another button. And it's definitely a break if you do any type of talking. If it's a segue, that's probably vague today, but I maintain it's still another element. In my time it was another slice on the clock and today it's another element in the automation playlist.
Others are not so vague...
Let's take WMC-FM, for example. They ID at :50...BUT they also run a jingle at the top of the hour that is basically a faux ID (FM-100 Memphis). Tell me that's not a break.
Why are folks ashamed of call letters now anyhow? ;D
If I'm legally sure...well, as you say that's pretty vague.
But in the old days, another song meant you had to push another button. And it's definitely a break if you do any type of talking. If it's a segue, that's probably vague today, but I maintain it's still another element. In my time it was another slice on the clock and today it's another element in the automation playlist.
Others are not so vague...
Let's take WMC-FM, for example. They ID at :50...BUT they also run a jingle at the top of the hour that is basically a faux ID (FM-100 Memphis). Tell me that's not a break.
Why are folks ashamed of call letters now anyhow? ;D
Being a recent Graduate, the legal ID was pounded into my head... What I was told was that it consisted of the call letters and city of licence.
ex. WUTM- Martin
it has to be at a natural break in programming, near the top of the hour. many stations that I know include one after the fifty break, before the next song. and as a sweeper type element at the top of the hour. (of course we do a sweeper between every song)
One guy I know has it hard timed to take over control of the station for two seconds at the top of every hour to give the ID (doesn't always sound good... but it's not my call).
anyway, there's my two cents.
I've never heard that the AM or FM was required.
ex. WUTM- Martin
it has to be at a natural break in programming, near the top of the hour. many stations that I know include one after the fifty break, before the next song. and as a sweeper type element at the top of the hour. (of course we do a sweeper between every song)
One guy I know has it hard timed to take over control of the station for two seconds at the top of every hour to give the ID (doesn't always sound good... but it's not my call).
anyway, there's my two cents.
I've never heard that the AM or FM was required.
P
PaulBWalkerJr
Guest
Here in Williston, our legal id is..
"Real COuntry 24 hours a day in AM Stereo, NewsRadio 660 K E Y Z WILLISTON......" AudioVault auto fades the song 8 seconds befor eTOH and fires that.
"Real COuntry 24 hours a day in AM Stereo, NewsRadio 660 K E Y Z WILLISTON......" AudioVault auto fades the song 8 seconds befor eTOH and fires that.
> What I was told was that it consisted of the call letters and city of licence.
Not always. The FCC allows some specific insertions. The applicable Rule:
"Official station identification shall consist of the station's call letters immediately followed by the community or communities specified in its license as the station's location: Provided, That the name of the licensee or the station's frequency or channel number, or both, as stated on the station's license may be inserted between the call letters and station location. No other insertion is permissible." 47 CFR §73.1201(b)(1).
> I've never heard that the AM or FM was required.
It is so required ONLY if a -FM, -TV, -DT, -CA, -CD, -LP, etc., is part of your LEGAL call sign. At the Martin station, there is no such suffix, so just the calls are required. But, take WHBQ as an example:
Here in Memphis, there is a WHBQ on 560 AM. It is simply WHBQ.
There is an FM on 107.5. Its legal call is WHBQ-FM
On TV, we have an analog on 13. It's WHBQ-TV legally.
WHBQ-TV has a digital service on channel 53. It's WHBQ-DT.
DE
Not always. The FCC allows some specific insertions. The applicable Rule:
"Official station identification shall consist of the station's call letters immediately followed by the community or communities specified in its license as the station's location: Provided, That the name of the licensee or the station's frequency or channel number, or both, as stated on the station's license may be inserted between the call letters and station location. No other insertion is permissible." 47 CFR §73.1201(b)(1).
> I've never heard that the AM or FM was required.
It is so required ONLY if a -FM, -TV, -DT, -CA, -CD, -LP, etc., is part of your LEGAL call sign. At the Martin station, there is no such suffix, so just the calls are required. But, take WHBQ as an example:
Here in Memphis, there is a WHBQ on 560 AM. It is simply WHBQ.
There is an FM on 107.5. Its legal call is WHBQ-FM
On TV, we have an analog on 13. It's WHBQ-TV legally.
WHBQ-TV has a digital service on channel 53. It's WHBQ-DT.
DE
> OK, DE so do the HD's have to ID?
Well, that's actually an interesting question.
Looking at the Rules, one gets no answer (which may be your answer). But, short of that, analysis of the question may be two steps:
1. The FCC has yet to assign distinct call signs to the HD sides of aural broadcast.
2. The FCC only requires a TV station to ID on either audio or video, despite the fact that really two completely distinct transmissions are happening (video and audio). See 47 CFR § 73.1201(a)(2).
So, I am assuming by analogy (could be wrong) that IDing on the main analog will do for all.
But, I could certainly see an argument to the opposite, especially on AM during critical hours.
Gosh, I love readin' Rule and Code sections!
Maybe we can find out how they do it in Williston.
DE
Well, that's actually an interesting question.
Looking at the Rules, one gets no answer (which may be your answer). But, short of that, analysis of the question may be two steps:
1. The FCC has yet to assign distinct call signs to the HD sides of aural broadcast.
2. The FCC only requires a TV station to ID on either audio or video, despite the fact that really two completely distinct transmissions are happening (video and audio). See 47 CFR § 73.1201(a)(2).
So, I am assuming by analogy (could be wrong) that IDing on the main analog will do for all.
But, I could certainly see an argument to the opposite, especially on AM during critical hours.
Gosh, I love readin' Rule and Code sections!
Maybe we can find out how they do it in Williston.
DE
D
DeltaKing
Guest
radiosaur said:
I think that the difference between radio and TV is that the DTV's are using an entirely new channel for their digital service, hence the requirement to ID. AM and FM are using their existing frequencies for HD broadcast, so they may be exempt.
Can anyone else shed light on this?
P
PaulBWalkerJr
Guest
DE:
maybe Im having a slight blonde moment, but was does ID'ing hafta do with critical hours?
maybe Im having a slight blonde moment, but was does ID'ing hafta do with critical hours?
> But I'm curious on the critical hours thing, too. DE.
I thought that would have been obvious.
As we know, HD on AM is limited to daylight hours. Further, as the sun begins to set before offical sunset, skywave is possible on MW (hence, "critical hours").
Now, we all know how HD works, spilling onto other channels. It may well be that as the skywave picks up, the HD signals will land somewhere where it is causing CCI. This is particularly concerning where that signal is causing interference on a "Clear" given to another country (e.g., Mexico, Canada, Bahamas). In this case, matters of international treaty would arise, which would trump FCC Rulemaking (Supremecy Clause, and all that). I am sure domestic broadcasters might also be a bit miffed.
If the main carrier were inaudible for whatever reason (most likely, interference on the main channel), it might well be appropriate to ID the HD channel.
But, I ain't a Commissioner.
I am not an opponent of IBOC, but I recognize that interesting issues can arise.
As an aside, though, I have not heard anyone comment on how well HD AM survives a hop off the ionosphere. As those schooled on such esoteric issues know, refraction through the ionosphere can do all sorts of odd things to a signal, and digital radio might be prone to dropping off the cliff in such cases. A few FM hobbyists this Summer, though, have heard usable signals from HD FM signals while they were bouncing off sporadic-E. But, is this analogous?
DE
I thought that would have been obvious.
As we know, HD on AM is limited to daylight hours. Further, as the sun begins to set before offical sunset, skywave is possible on MW (hence, "critical hours").
Now, we all know how HD works, spilling onto other channels. It may well be that as the skywave picks up, the HD signals will land somewhere where it is causing CCI. This is particularly concerning where that signal is causing interference on a "Clear" given to another country (e.g., Mexico, Canada, Bahamas). In this case, matters of international treaty would arise, which would trump FCC Rulemaking (Supremecy Clause, and all that). I am sure domestic broadcasters might also be a bit miffed.
If the main carrier were inaudible for whatever reason (most likely, interference on the main channel), it might well be appropriate to ID the HD channel.
But, I ain't a Commissioner.
I am not an opponent of IBOC, but I recognize that interesting issues can arise.
As an aside, though, I have not heard anyone comment on how well HD AM survives a hop off the ionosphere. As those schooled on such esoteric issues know, refraction through the ionosphere can do all sorts of odd things to a signal, and digital radio might be prone to dropping off the cliff in such cases. A few FM hobbyists this Summer, though, have heard usable signals from HD FM signals while they were bouncing off sporadic-E. But, is this analogous?
DE
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