FCC issues NOV to KRVH-FM Rio Vista,

[Frequency1]

NOTICE OF VIOLATION Released: March 2, 2020
By the Regional Director, Region Three, Enforcement Bureau:
1. This is a Notice of Violation (Notice) issued pursuant to section 1.89 of the Commission’s rules (Rules) to River Delta Unified School District (RDUSD) licensee of radio station KRVH in Rio Vista, California. Pursuant to section 1.89(a) of the Rules, issuance of this Notice does not preclude the Enforcement Bureau from further action if warranted, including issuing a Notice of Apparent Liability for Forfeiture for the violation(s) noted herein.

2. On November 30, 2018, Agents of the Enforcement Bureau’s San Francisco Office monitored radio station KRVH, and observed the following violation(s): a. 47 CFR § 11.52(d)(1): EAS Code and Attention Signal Monitoring Requirements. “With respect to monitoring for EAS messages that are formatted in accordance with the EAS Protocol, EAS Participants must monitor two sources. The monitoring assignments of each broadcast station and cable system and wireless cable system are specified in the State EAS Plan and FCC Map Book. They are developed in accordance with FCC monitoring priorities.” KHRV is located in Solano County, California. According to the State of California Emergency Alert System Plan, Version 2.0, dated October 11, 2017, the two sources of monitoring assignments for Solano County would be under the San Francisco Bay Counties Plan, KCBS 740 kHz and KFRC 106.9 MHz. At the time of inspection, the Agent noted that KRVH was not monitoring either of those sources. Rather, KRVH was monitoring KFBK 1530 kHz, and the National Weather Service on 162.55 MHz.

b. 47 CFR § 73.1201(b)(1): Station Identification. “Content. 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; [p]rovided, [t]hat the name of the licensee, the station’s frequency, the station’s channel number, as stated on the station’s license, and/or the station’s network affiliation may be inserted between the call letters and station location.” At the time of the inspection the Agent noted that the station identification did not specifically state the community of license.

c. 47 CFR § 73.1870(a) and (b)(3): Chief Operators. “The licensee of each AM, FM, TV or Class A TV broadcast station must designate a person to serve as the station’schief operator. At times when the chief operator is unavailable or unable to act (e.g., vacations, sickness), the licensee shall designate another person as the acting chief operator on a temporary basis.… The designation of the chief operator must be in writing. Agreements with chief operators serving on a contract basis must be in writing with a copy kept in the station files.” At the time of inspection KRVH had not designated a Chief Operator and there was no letter posted with the station files designating the chief operator.

d. 47 CFR § 73.1690(c)(1): Modification of Transmission Systems. “The following FM, TV and Class A TV station modifications may be made without prior authorization from the Commission. A modification of license application must be submitted to the Commission within 10 days of commencing program test operations pursuant to § 73.1620.... Replacement of an omnidirectional antenna with one of the same or different number of antenna bays, provided that the height of the antenna radiation center is not more than 2 meters above or 4 meters below the authorized values....” KRVH’s station license specifies the antenna type as an omnidirectional (Non-Directional) Jampro JLCP-2. The installed antenna does not meet the same description as specified by Jampro literature for the JLCP-2 antenna. Therefore, RDUSD was required to notify the Commission of this antenna change within 10 days of commencing program test operations.We seek additional information concerning the violation and any remedial actions taken. Therefore, RDUSD must submit a written statement concerning this matter within twenty (20) days of release of this Notice. The response (i) must fully explain each violation, including all relevant
surrounding facts and circumstances, (ii) must contain a statement of the specific action(s) taken to
correct each violation and preclude recurrence, and (iii) must include a time line for completion of any
pending corrective action(s). The response must be complete in itself and must not be abbreviated by
reference to other communications or answers to other notices.

4. In accordance with section 1.16 of the Rules, we direct RDUSD to support its response to
this Notice with an affidavit or declaration under penalty of perjury, signed and dated by an authorized
officer of RDUSD with personal knowledge of the representations provided in RDUSD’s response,
verifying the truth and accuracy of the information therein, and confirming that all of the information
requested by this Notice which is in RDUSD’s possession, custody, control, or knowledge has been

 

[seattlesarchiebunker]

I thought class D stations were not required to participate in EAS?

For somebody uninformed (ignorance is no excuse for breaking the rules, I know) like a HS radio teacher who may not have much tech experience, in a place like Rio Vista with better signals from Sacramento stations than the EAS stations they are supposed to follow in SF (I'd probably argue more listenership to Sac stations out there too), at least the EAS Primary makes sense.

Everything seems to be fairly easy to fix in short order without paying out much cash...which is nice. There aren't many class D stations left anymore. Many of the ones that are tend to be left to rot on the vine and get turned in when participation drops or something becomes too pricey for the license holders to repair.

 

[TheBigA]

This is why high schools across the country are getting out of the towers and transmitters business. It's expensive, and then something like this happens.

You don't have these kinds of problems with unregulated online radio. I can hear the school board calling EMF right now.

 

[seattlesarchiebunker]

Also, there's just less interest from high schoolers/college students in pursuing radio either as a hobby or as a career. Considering many kids these days don't really interact with radio in the same way we did 20-50 years ago, that's not surprising. That alone has been the death knell for scores of class D's and low-powered class A's. "Lack of student participation". Combine that with aging equipment (grandfathered class D's are over 40 years old now), and the age-old argument over public school funding...it looks bleak for many high school operations.

It seems class D stations are virtually unsaleable unless you're in the middle of a big market, ditto with low-powered class A's that can't be upgraded. Most just get shut down and turned in because the "big guns" like EMF or NPR affiliates just don't want the pain of maintaining another license that barely gets any listeners. Of course, there are always exceptions to the rule (but I can't think of any off the top of my head)

I wouldn't be surprised if KVHS in Concord gives up the ghost at some point and sells. The imaging has been the same for about a decade...never any students I hear behind the mic...Which is a shame because I have liked their active rock format and it blasts in up here in the Gold Country.

 

[Michael Rivers Kramer]

I thought class D stations were not required to participate in EAS?

For somebody uninformed (ignorance is no excuse for breaking the rules, I know) like a HS radio teacher who may not have much tech experience, in a place like Rio Vista with better signals from Sacramento stations than the EAS stations they are supposed to follow in SF (I'd probably argue more listenership to Sac stations out there too), at least the EAS Primary makes sense.

Everything seems to be fairly easy to fix in short order without paying out much cash...which is nice. There aren't many class D stations left anymore. Many of the ones that are tend to be left to rot on the vine and get turned in when participation drops or something becomes too pricey for the license holders to repair.

Adding insult to this is the fact the Rio Vista is in the Sacramento/Stockton/Modesto DMA, but in the San Francisco Radio Market.

 

[Ralph Martin]

I know this about KRVH:

They are an engaged and vital part of their community. I know that their kids do daily live programming. I know that they broadcast play-by-play sports for their school.

I know this because our football team plays theirs and when they do, both their station and ours are out there covering the game for our respective communities. When it happens, it's amazing to see their kids talking shop with our kids. High school radio is an important part of the radio landscape!

I know they'll get through this. I wish them well. We need more school programs like KRVH to engage the kids in a positive direction.

I would encourage working or retired broadcast engineers to visit their local high school station on occasion and help them through some of the small necessities to keep them on the air and in good condition.

Listen to an active high school radio station. Watch them in action. You'll know right away that it's worth the effort!