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The owner of K223CW is a scofflaw and all their translators are breaking the rules. It’s different when a small AM station with a translator keeps the translator on for a week when the AM transmitter breaks. But when a translator originates programming and runs over 1000 watts, that’s an unfair advantage for the translator.
That's quite the accusation. Do you have any substantive proof?
 
Yes. K223CW did get inspected. There also was a picture of the transmitter putting out 2000 watts. The inspector saw it running 400 watts and it had no primary station
So the Commission visited it and saw it was putting out 2kW, or you've seen a photo of a wattmeter that indicates 2kW?
According to licensing records; K223CW parent is KFNC-FM. The licensed VERP is 30 watts. I can't imagine a translator licensed for 30W VERP running with a TPO of 2kW. Either there's something that doesn't pass the sniff test on your report, or that's the most blatant over-power condition on a Class D translator in history.
 
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In reviewing some of the many correspondence files between Centro Christiano De Vida Eterna, licensee of K223CW and the Commission, it looks like there was a messy divorce where Hector Salvador Guevara's wife ended up with the stations/translators, and intended on donating them to someone else. Quite the soap opera!
I didn't see any NAL's that would indicate K223CW was caught running 1,972W over the CP limit, let alone as you claim was caught running 372W over power.
 
I didn't see any NAL's that would indicate K223CW was caught running 1,972W over the CP limit, let alone as you claim was caught running 372W over power.
This was posted to the Houston thread earlier https://docs.fcc.gov/public/attachments/DOC-398508A1.pdf . And you just have to drive around Houston to tell just how powerful that translator (and others). Also I’ve personally heard the translator has different programming from KFNC and would ID as KFNC HD2 but that station has not had HD (at least within the last 10 years or so).
 
This was posted to the Houston thread earlier https://docs.fcc.gov/public/attachments/DOC-398508A1.pdf . And you just have to drive around Houston to tell just how powerful that translator (and others). Also I’ve personally heard the translator has different programming from KFNC and would ID as KFNC HD2 but that station has not had HD (at least within the last 10 years or so).
I'm sorry, but driving around listening to a station on your car radio is not a scientific nor accepted way of confirming that a station is running over its authorized power. It's no more an accepted methodology than trying to determine field strength using an S-meter on an older stereo receiver.
 
I'm sorry, but driving around listening to a station on your car radio is not a scientific nor accepted way of confirming that a station is running over its authorized power. It's no more an accepted methodology than trying to determine field strength using an S-meter on an older stereo receiver.
C'mon, Kelly. I know playing devil's advocate is part of your schtick here, but there's extremely clear evidence that this particular translator violated multiple rules.

There is no KFNC-HD2 originating it, yet 92.5 originates its own programming (including a full season of Sugar Land baseball). Even if there were an HD2 from KFNC, the translator's licensed contour exceeds KFNC's licensed 60, so it can't legally be a fill-in at 250 watts.

And the FCC EB caught them at well above licensed power.

What are you trying to defend here? And why?
 
C'mon, Kelly. I know playing devil's advocate is part of your schtick here, but there's extremely clear evidence that this particular translator violated multiple rules.

There is no KFNC-HD2 originating it, yet 92.5 originates its own programming (including a full season of Sugar Land baseball). Even if there were an HD2 from KFNC, the translator's licensed contour exceeds KFNC's licensed 60, so it can't legally be a fill-in at 250 watts.
Read what I said Scott. You of all people should know that driving around is not a calibrated indicator that a station is running over it's licensed power. That's what I was commenting on, not whether their programming is provided to the translator via whatever HD2.
 
You and I are both experienced engineers. You mean to tell me that you can't drive signal and tell if it's overperforming in a way that indicates it has to be running more than licensed power by a significant amount?

I wouldn't use that technique to attach a specific power level to a station, but if it's an order of magnitude too high, especially in what's supposed to be a DA null, it becomes pretty obvious.
 
I interviewed the "engineer" for two translators that wanted to go on the 1,400' platform of the Senior Road Tower several years ago.

He was planning to install 2kW transmitters in an enclosure on the platform, and a 3 bay, full-wave spaced, circularly polarized antenna and combine both translators into it.

I asked him why he needed 2kW transmitters when the antenna would be mere feet from the transmitter enclosure and there would be no line loss to speak of. He didn't have an answer.

Then I asked him why with that much transmitter, he needed antenna gain of 1.5. No answer for that either.

The most fun question though was when I asked him how he planned to make the directional patter that one of the translators required using this antenna. The license for one of the translators called for two yagis pointing in different directions, about 120 degrees apart, and notably, away from Houston.

His response was "Oh, I need a special antenna for that?"

2kW TPO, virtually no line loss, antenna gain of 1.5 - after the combiner, this likely would have resulted in 2.5kW or so ERP.

Senior Road decided to decline this opportunity, and likely dodged a huge bullet in the process.

The "engineer" that I interviewed has run into serious candor issues with the FCC on multiple occasions.
 
Read what I said Scott. You of all people should know that driving around is not a calibrated indicator that a station is running over it's licensed power.
It’s not at all scientific. But I know something fishy is up when I can hear that translator 55 miles to the north and the licensed directional pattern shouldn’t even touch New Waverly or Shepherd.


I could talk about these sketchy translators all day but on this thread I’ll only be talking about HD stations or translators that actually involve HD.
 
You and I are both experienced engineers. You mean to tell me that you can't drive signal and tell if it's overperforming in a way that indicates it has to be running more than licensed power by a significant amount?

I wouldn't use that technique to attach a specific power level to a station, but if it's an order of magnitude too high, especially in what's supposed to be a DA null, it becomes pretty obvious.
Depending on my knowledge of the station in question, I might notice something, but would never make the mistake of jumping to the conclusion that the station was running something other than licensed power based on my vehicle radio. Over the years I've dealt with hobbyists or listeners who accused one of my stations from being over-power because they're hearing it where they aren't accustomed to. Come to find out, it was merely an instance of VHF ducting ahead of a thunder storm.
 
Senior Road decided to decline this opportunity, and likely dodged a huge bullet in the process.

The "engineer" that I interviewed has run into serious candor issues with the FCC on multiple occasions.
And a smart landlord would check what is being proposed by a tenant vs. what is on the C.P. I recognize that there are some shady folks that call themselves engineers, but fortunately from what I've found, they're few and far between.
 
And a smart landlord would check what is being proposed by a tenant vs. what is on the C.P. I recognize that there are some shady folks that call themselves engineers, but fortunately from what I've found, they're few and far between.
This guy actually wasn't the "engineer" though that's how he was introduced to me by his broker.

He was the owner, but not the licensee. (Yes, I get the contradiction, but apparently, this guy can't be a licensee for whatever reason, and utilizes intermediaries.)

The licenses were issued to a local church.
 
This guy actually wasn't the "engineer" though that's how he was introduced to me by his broker.

He was the owner, but not the licensee. (Yes, I get the contradiction, but apparently, this guy can't be a licensee for whatever reason, and utilizes intermediaries.)

The licenses were issued to a local church.
Welcome to Houston.
 
Depending on my knowledge of the station in question, I might notice something, but would never make the mistake of jumping to the conclusion that the station was running something other than licensed power based on my vehicle radio. Over the years I've dealt with hobbyists or listeners who accused one of my stations from being over-power because they're hearing it where they aren't accustomed to. Come to find out, it was merely an instance of VHF ducting ahead of a thunder storm.
We have a lot of tropo here, but not 365 days per year.

Several of the translators here can be caught reliably 30 to 40 miles from their transmitters - even in the null of the directional pattern on their license - all day, every day.

They were shady before they were even built. Many, if not most of the Houston translators were hopped into Houston on paper, without any of the hop sites having been built. They would file for the license to cover without even having a lease in place at the supposed transmitter site.

A Houston based "church" that happens to own several Houston translators was busted by a Chicago engineer while trying to pull that stunt there, including claiming they had broadcast for a while from the tower of 50kW WSCR as one of their hop sites. Oddly, WSCR's owner had no knowledge of this arrangement. The Chicago engineer apparently wasn't being directed to keep his mouth shut by corporate attorneys, like many of the Houston engineers were.

FCC Report 3/18: What’s Next For The Chicago Ghost Translator - RadioInsight
 
And a smart landlord would check what is being proposed by a tenant vs. what is on the C.P. I recognize that there are some shady folks that call themselves engineers, but fortunately from what I've found, they're few and far between.
This subject involves some complicated and unresolved legal questions that the Courts have yet to address. In recent years, the FCC enacted rules that attempt to subject landlord property owners to liability when their broadcast tenants operate without a license, or outside their licensed parameters. But does a landlord legally have a right to enter a leased spaced occupied by a tenant for any reason other than an emergency or to perform routine maintenance? Does a landlord have a obligation to check the FCC database to ensure that their tenants' broadcast licenses are valid and not expired? Does a landlord have an obligation to hire engineering consultants to make regular inspections of their tenants' equipment to be sure they are at the right power level or using the correct antenna?

While the FCC's intentions may have been good, they are on very shaky legal grounds. Imagine if the Dallas or Houston city police passed a rule telling owners of apartment complexes that they are going to be held liable for the criminal acts of their tenants. A maritial dispute involves a man slapping his wife in their rented apartment, so lets hold the landlord responsible for the assault. A young man decides to start bleaching one dollar bills and using a copier in his apartment to print $20 on the paper, so let's require the landlord to give restitution to the businesses who lost revenue due to counterfeiting. Here we have a very slippery slope where landlords essentially become agents of the government. Landlords would have to start entering apartments unannounced to make sure their tenants are not smoking weed or using drugs. They would have to watch bedrooms to make sure acts of prostitution are not taking place.

A landlord is not the police nor the FCC, and thus has no business trying to regulate the activities of a paying tenant.
 
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This subject involves some complicated and unresolved legal questions that the Courts have yet to address. In recent years, the FCC enacted rules that attempt to subject landlord property owners to liability when their broadcast tenants operate without a license, or outside their licensed parameters.
Actually, Congress enacted a law, Public Law No: 116-109. It only addresses unlicensed operation and landlords. The law says nothing about licensed stations operating outside licensed parameters. Is Congress on shaky ground with this law? That is for the courts to decide but, until then, it is the “law of the land.”
While the FCC's intentions may have been good, they are on very shaky legal grounds. Imagine if the Dallas or Houston city police passed a rule telling owners of apartment complexes that they are going to be held liable for the criminal acts of their tenants. A maritial dispute involves a man slapping his wife in their rented apartment, so let’s hold the landlord responsible for the assault.

A landlord is not the police nor the FCC, and thus has no business trying to regulate the activities of a paying tenant.
But a landlord can be held liable if they knowingly allow illegal activity. To use your example, a man slaps his wife and the landlord observes it but takes no action. Latter, the same man that slapped his wife, assaults another tenant. The victim of that assault may have a valid civil case against the landlord as the landlord knew of the illegal activity and did nothing.

I am not an attorney nor do I represent myself as one…..
 


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