Not to be geeky/nitpicky... but I keep hearing the KROQ TOH ID say "KROQ-FM and HD2." Shouldn't it be HD1 instead, since the HD2 is a separate channel?
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KROQ legal ID
- Thread starter RockTheGlobe
- Start date
OK, I'm talking out of my ass here, not knowing anything about HD radio, but I'm guessing that on an HD radio 106.7FM-HD1 is the regular feed that everyone else gets and HD2 is the dedicated HD channel. I believe they subdivide the frequencies, so the "2" refers to the second subdivision.
106.7 FM | KROQ Alternative | Pasadena, CA
106.7 HD1 | KROQ (KROQ-HD1) - Alternative | Pasadena, CA
106.7 HD2 | KROQ2 (KROQ-HD2) - The Roq Of The 80s! 80's, Classic Alternative/Modern Rock | Pasadena, CA
The ID really should be "KROQ FM and KROQ HD1 Pasadena-Los Angeles-Orange County" or
I'd guess they could get by with "KROQ and KROQ HD1 ..." or "KROQ FM and HD1 ...".
As mentioned by RockTheGlobe, KROQ HD2 is a separate channel with separate programming, thus it should not be included with the "main station" (primary channel) ID.
On KROQ2, the ID is "KROQ HD2 Pasadena-Los Angeles-Orange County".
106.7 HD1 | KROQ (KROQ-HD1) - Alternative | Pasadena, CA
106.7 HD2 | KROQ2 (KROQ-HD2) - The Roq Of The 80s! 80's, Classic Alternative/Modern Rock | Pasadena, CA
The ID really should be "KROQ FM and KROQ HD1 Pasadena-Los Angeles-Orange County" or
I'd guess they could get by with "KROQ and KROQ HD1 ..." or "KROQ FM and HD1 ...".
As mentioned by RockTheGlobe, KROQ HD2 is a separate channel with separate programming, thus it should not be included with the "main station" (primary channel) ID.
On KROQ2, the ID is "KROQ HD2 Pasadena-Los Angeles-Orange County".
I believe this is incorrect. The rule states that the COL must follow the call letters (although the name of the licensee, frequency, channel or network may be inserted in between). But the rule is clear that you can't have a series of call letters preceding the COL. A minimal legal ID would be "KROQ-FM Pasadena [and] KROQ-FM-HD1 Pasadena". That takes care of the analog signal and the primary digital stream.
Similarly, a station ID "KFUD and KFUD-FM, Podunk" or "KFUD AM and FM, Podunk" are not in compliance with the rule. For starters, there is no such thing as an "AM" suffix. All AM stations are suffix-less.
http://cfr.vlex.com/vid/73-1201-station-identification-19852453
Except as pointed out in a dozen other threads on legal IDs, the FCC really doesn't care - and has never cared - as long as the legal ID is close to the requirement.chris319 said:
So if "KFUD AM and FM, Podunk" sounds better than "KFUD and KFUD-FM, Podunk," nobody cares.
Similarly, "From beautiful downtown Podunk, KFUD..." would also pass muster.
Lkeller said:
Perhaps not today but twenty years ago I encountered a field inspector that did care. The station was called, using the example above, "99FUD". The jock did a live ID as "99, KFUD Podunk". The facility was going through a surprise inspection and the file inspector heard the ID. He informed the jock the proper legal ID for the station was "99.1 KFUD Podunk". The field inspector was already a holy terror so we obliged for a day and returned to the way we've done it. Were we in the right? Yes. But a field inspector with an attitude is right for the moment.
There's no way to start your day like getting a call from the station receptionist at 10:00 am sharp saying "There's an FCC inspector here." Been there, done that.
I have been known to drive at the breakneck speed of 70 mph on roads where the posted speed limit was 65 mph. I've never been pulled over and cited for doing so. Still, an officer would be within the law to pull me over and issue me a ticket. Don't confuse laxity on the part of law enforcement with "passing muster" or being in compliance. A station will not lose a single listener because they give a station ID which is in compliance with the rules, I guarantee it.
Now really, how does it harm the station's branding to use the legal ID once an hour? "99-point-1 K-F-U-D, Podunk ... 99FUD" or "K-F-U-D 99-point-1 Podunk ... 99FUD" or just "K-F-U-D Podunk ... 99FUD" are all legal and maintain the branding. Or borrow from the movies and say "99-point-1 K-F-U-D, Podunk is 99FUD". A manager who doesn't get that should excuse him/herself from the business, FCC indifference or no.
I have been known to drive at the breakneck speed of 70 mph on roads where the posted speed limit was 65 mph. I've never been pulled over and cited for doing so. Still, an officer would be within the law to pull me over and issue me a ticket. Don't confuse laxity on the part of law enforcement with "passing muster" or being in compliance. A station will not lose a single listener because they give a station ID which is in compliance with the rules, I guarantee it.
Now really, how does it harm the station's branding to use the legal ID once an hour? "99-point-1 K-F-U-D, Podunk ... 99FUD" or "K-F-U-D 99-point-1 Podunk ... 99FUD" or just "K-F-U-D Podunk ... 99FUD" are all legal and maintain the branding. Or borrow from the movies and say "99-point-1 K-F-U-D, Podunk is 99FUD". A manager who doesn't get that should excuse him/herself from the business, FCC indifference or no.
chris319 said:
Being a radio geek, I love those times when a station has changed branding, but the call letters haven't caught up with new "brand" yet. I recall an example in the Bay Area in which "K-Big" (KBGG) had become "Kiss-FM." For a couple of months, until Clear Channel got approval to change calls to KISQ, the legal TOH ID ("KBGG, San Francisco") would be whispered really quickly. Apparently this counts as compliance, and would seem to indicate that managers are a bit obsessed with the branding.
I am not an FCC field agent, or a communications lawyer. But...I've studied 73.1201 in its various incarnations over the years and I can't even begin to figure out where "99 KFUD Podunk" violates the strict letter of rule as it's ever been laid out. The rule has always required that the callsign be stated, followed by the COL, sometimes with various insertions allowed between the two. It has never regulated what's said before the callsign or after the COL. So as long as the station said "KFUD Podunk," and it did, everything around that was not content subject to 73.1201.
Having said that: the Commission has certainly attempted to regulate some of that content over the years regardless of the letter of 73.1201. Think about "KABL Oakland" (legal) ", in the air everywhere over San Francisco." (outside the official legal ID, but deemed by FCC field agents to represent an illegal identification with an additional city, circa 1960.) Today, that ID wouldn't be considered in any way illegal, save for the fact that KABL has changed calls since then.
Returning to KROQ, and laying aside the questionable use of "HD2" instead of "HD1," the FCC muddied the legal ID waters massively when it introduced a new requirement that:
The lawyers at CBS (and Clear Channel, and Cumulus, and dozens of other companies that also ID as "KXXX and KXXX-HD1, Anytown") appear to have determined that "and KXXX-HD1" is such an appropriate manner of identifying that digital signal. The FCC has taken no enforcement action that would suggest otherwise. And the rule is so vague in its wording that it would be hard to argue otherwise.
Having said that: the Commission has certainly attempted to regulate some of that content over the years regardless of the letter of 73.1201. Think about "KABL Oakland" (legal) ", in the air everywhere over San Francisco." (outside the official legal ID, but deemed by FCC field agents to represent an illegal identification with an additional city, circa 1960.) Today, that ID wouldn't be considered in any way illegal, save for the fact that KABL has changed calls since then.
Returning to KROQ, and laying aside the questionable use of "HD2" instead of "HD1," the FCC muddied the legal ID waters massively when it introduced a new requirement that:
The lawyers at CBS (and Clear Channel, and Cumulus, and dozens of other companies that also ID as "KXXX and KXXX-HD1, Anytown") appear to have determined that "and KXXX-HD1" is such an appropriate manner of identifying that digital signal. The FCC has taken no enforcement action that would suggest otherwise. And the rule is so vague in its wording that it would be hard to argue otherwise.
The station was called, using the example above, "99FUD". The jock did a live ID as "99, KFUD Podunk". The facility was going through a surprise inspection and the file inspector heard the ID. He informed the jock the proper legal ID for the station was "99.1 KFUD Podunk". The field inspector was already a holy terror so we obliged for a day and returned to the way we've done it.
The issue is that 99 KFUD Podunk is a legal ID. The "99" ahead is irrelevant, as would be the addition of "East Podunk and the Podunk Valley" to the ending.
The FCC inspector was wrong.
In fact, frequency rounding in analog days was so common I know of at least one station that had the license holder name change to match the rounded frequency: "KFUD, FM 99, Podunk" because the licensee was "FM 99 Inc."
The need for IDs dates back to the interference complaint era of early technology... the 20's and perhaps the 30's. Most nations have no call letter ID requirements, and stations establish brands that are superior to bunches of letters.
If we need a unique identifier, use the embedded PPM technology and be done with it. The FCC uses Arbitron data to define markets for ownership cap determination. Why not use the unique ID that PPM encoders produce to eliminate the ID requirement from the listener-intended audio of every station?
At some point, old, useless rules need to be changed to reflect the times and technology.
chris319 said:
The issue is that 99 KFUD Podunk is a legal ID. The "99" ahead is irrelevant, as would be the addition of "East Podunk and the Podunk Valley" to the ending.
The FCC inspector was wrong.
In fact, frequency rounding in analog days was so common I know of at least one station that had the license holder name change to match the rounded frequency: "KFUD, FM 99, Podunk" because the licensee was "FM 99 Inc."
The need for IDs dates back to the interference complaint era of early technology... the 20's and perhaps the 30's. Most nations have no call letter ID requirements, and stations establish brands that are superior to bunches of letters.
If we need a unique identifier, use the embedded PPM technology and be done with it. The FCC uses Arbitron data to define markets for ownership cap determination. Why not use the unique ID that PPM encoders produce to eliminate the ID requirement from the listener-intended audio of every station?
At some point, old, useless rules need to be changed to reflect the times and technology.
The inspector likely felt, rightly or wrongly, that "99" misstated the frequency and should have been given as "99-point-1". Sounds like this guy was on a tear anyway.
Here you go:
https://groups.google.com/forum/?hl=en&fromgroups=#!topic/ba.broadcast/EEKon2-kZlY
My mother used to listen to KABL back in the day. My recollection was that they used to say "K-A-B-L, San Francisco, Oakland, in the air everywhere over San Francisco" finishing with the "clang-clang" of a cable car bell. Inasmuch as this was %$#@ years ago, my recollection may have grown a little fuzzy.
KIIS-FM:
on the xm/sirius TOH id - is very motivational !!!
*I enjoy the PRODUCTION* and the voice/work!!
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>conversely, it would be funny...if the legal ID was just
(in big market LA) a guy clearing his throat and simply
reading "KROQ-FM is frequencey 106.9 FM - and it
serves Pasadena, (Hollywood)LOL* and Orange County, Enjoy!"
on the xm/sirius TOH id - is very motivational !!!
*I enjoy the PRODUCTION* and the voice/work!!
-
>conversely, it would be funny...if the legal ID was just
(in big market LA) a guy clearing his throat and simply
reading "KROQ-FM is frequencey 106.9 FM - and it
serves Pasadena, (Hollywood)LOL* and Orange County, Enjoy!"
I know cbs in Houston for kkhh the actual "legal" id is said faster than your ears can hear it (great female voice btw) and they separate the two (regular and hd) just perfectly. as far as keeping calls and still making stations use them once an hour, i'm all for it! it is a part of radio that should never die
chris319 said:
Here are some links to Broadcasting Magazine reports at the time (1966)
http://www.americanradiohistory.com...2-19-BC-0046.pdf#search="kabl identification"
http://www.americanradiohistory.com...0-03-BC-0051.pdf#search="kabl identification"
KABL identified as "Cable, KABL, Oakland, in the air, everywhere, over San Francisco."
"KABL-San Francisco-Oakland" would have been patently illegal; as it was, the FCC thought the mere proximity of "San Francisco" to the legal ID was misleading.
I remember in the mid 80s when KIIS simulcast on 102.7 and 1150, they made a big deal out of the TOH legal ID for both which I always thought was cool (most stations even then tried to bury it is as much as possible).
Big booming voice with background sound effects "This is K-I-I-S FM and AM, Los Angeles"
It was a big deal back then because a lot of radios, especially in old cars, were AM only. So by making a big deal out of the legal ID, what they were really implicitly saying to their core audience was "Even if you're stuck in Mom's old station wagon, you can still tune into KIIS, your favorite FM station". Which is exactly what my cousin and I did when we had to tool around in Grandma's old Pinto.
Big booming voice with background sound effects "This is K-I-I-S FM and AM, Los Angeles"
It was a big deal back then because a lot of radios, especially in old cars, were AM only. So by making a big deal out of the legal ID, what they were really implicitly saying to their core audience was "Even if you're stuck in Mom's old station wagon, you can still tune into KIIS, your favorite FM station". Which is exactly what my cousin and I did when we had to tool around in Grandma's old Pinto.
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