R
[email protected]
Guest
Transmitter readings and signatrures when live on progam logs at a college non-comm All this has been deregulated years ago?? Yes/No??
Thanx
RadioRohn in Nj
Thanx
RadioRohn in Nj
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Transmitter Readings and Program Logs being signed?
- Thread starter [email protected]
- Start date
A friendly word of advice, if I may?
You'll find some folks here on the boards who know exactly what they're talking about. You'll find many more who think they do, even when they don't.
The FCC's fines for public-file violations now run somewhere in the neighborhood of $7,000. Operational violations can run that tab up even higher. A quick consultation with a DC communications lawyer will cost much less than that, and you'll come away with real answers that can keep you out of a lot of expensive trouble down the road.
(Failing that, since you're at a noncomm, at least do a search for the "Pubtech" mailing list and get yourself on it; the advice you'll get there is free, but rather more trustworthy than a bunch of anonymous message-board posters.)
You'll find some folks here on the boards who know exactly what they're talking about. You'll find many more who think they do, even when they don't.
The FCC's fines for public-file violations now run somewhere in the neighborhood of $7,000. Operational violations can run that tab up even higher. A quick consultation with a DC communications lawyer will cost much less than that, and you'll come away with real answers that can keep you out of a lot of expensive trouble down the road.
(Failing that, since you're at a noncomm, at least do a search for the "Pubtech" mailing list and get yourself on it; the advice you'll get there is free, but rather more trustworthy than a bunch of anonymous message-board posters.)
To answer your particular question, transmitter readings are not needed, but you should have some kind of log that indicates when you've sent and received EAS tests, and, if you have a lighted tower, a daily check of the tower lights.
However, as Scott notes, the Commission is more concerned with the public file than just about anything else nowadays. Except, perhaps, that 12 noon broadcast of George Carlin's "Seven Words You Can't Say on the Radio." And yes, they will fine non-comms. Our greedy government at work. Prime Example: $5k fine on Holy Cross College's 100 watter in Worchester, Mass., a few years ago.
So I would concentrate on your public file.
Here's a link to a series of checklists from the FCC that should prove helpful:
http://www.fcc.gov/Document_Indexes/Enforcement/2003_index_EB_Fact_Sheet.html
However, as Scott notes, the Commission is more concerned with the public file than just about anything else nowadays. Except, perhaps, that 12 noon broadcast of George Carlin's "Seven Words You Can't Say on the Radio." And yes, they will fine non-comms. Our greedy government at work. Prime Example: $5k fine on Holy Cross College's 100 watter in Worchester, Mass., a few years ago.
So I would concentrate on your public file.
Here's a link to a series of checklists from the FCC that should prove helpful:
http://www.fcc.gov/Document_Indexes/Enforcement/2003_index_EB_Fact_Sheet.html
Transmitter readings do not have to be logged...but they must be correct for your licensed power level. If you are inspected by the FCC and they find your transmitter is operating at a power level other than the licensed value they may ask for proof that this not how it always operates.
What better way to prove that you have been operating legally than to show them "logs" of transmitter readings ? While transmitter logs are not required they can be helpful.
What better way to prove that you have been operating legally than to show them "logs" of transmitter readings ? While transmitter logs are not required they can be helpful.
If you have an AM station, be certain the fence around the tower is in good condition...that has a habit of drawing fines far in excess of what a new fence costs. Fence, EAS & Public File are the biggies. Sadly things that really matter like Over-Power, Over-Modulation, Operating with Daytime Facilities at night and out of tolerance directional AM systems aren't on the FCC radar very often. It requires technical skill to verify those items, whereas a Fence, EAS Log & Public File completeness can be handled by bureaucrats.
Yes. For the most part it's things that don't require as much tech savvy on their part to fine a person. I will say though that they still like to terrorize directional AMs, especially higher powered ones...
We use a yahoo calendar program. Each week I electronically sign the log on Friday. I include all the sent and received tests on the day they were received. btw - This is supposed to be in the public file.
Why hire an attorney? 3 of 4 attorneys have differing views. Perform a self inspection (free) and keep it to document your operation. OR - have your state broadcasters assn do a mock inspection. Same thing except they document it.
We had the state inspection every 3 years for at least 9 years and someone discovered our tower was at the wrong place. Tower was pre electronic document and plotted wrong by the cable company in 1970. We corrected it with the FCC. Sometimes they are anal in the inspection areas to keep you fine free.
Why hire an attorney? 3 of 4 attorneys have differing views. Perform a self inspection (free) and keep it to document your operation. OR - have your state broadcasters assn do a mock inspection. Same thing except they document it.
We had the state inspection every 3 years for at least 9 years and someone discovered our tower was at the wrong place. Tower was pre electronic document and plotted wrong by the cable company in 1970. We corrected it with the FCC. Sometimes they are anal in the inspection areas to keep you fine free.
Do not put anything in the "Public File" that is not required to be there. The EAS logs, tower lighting logs, etc., cited earlier, instead belong in the "Station Log." Only the "Public File" is open to the public, so don't put non-required items in there, with the concomitant unnessary exposure that engenders. The FCC, of course, does have the authority to inspect them, along with any other records you may retain, required or not, so choose wisely.
N
necrat123
Guest
I haven't seen it mentioned yet but make sure your tower lighting/painting system is up to snuff too.
Make sure it is logged when outages have occured and when they have been corrected.
Make sure the tower light monitoring system is working too.
Remember when it comes to the tower lighting, Pilots can and will report to the FAA if they spot a problem with it, and the FAA will
contact the FCC on it.
Make sure it is logged when outages have occured and when they have been corrected.
Make sure the tower light monitoring system is working too.
Remember when it comes to the tower lighting, Pilots can and will report to the FAA if they spot a problem with it, and the FAA will
contact the FCC on it.
Scott's advice is good. I'd also follow up by suggesting that if you have any questions about compliance at your station that you participate in the Alternative Broadcast Inspection Program. I'm assuming you are in New Jersey - the New Jersey Broadcaster's Association administers the program in the state. You pay a fee, a consulting engineer comes in and inspects your operation. If there are compliance issues, you are advised as to how to address them. If found to be in compliance, you get a certificate. Hang it in your lobby and the FCC will not inspect your station on a "random" basis for the validity period of the certificate. They may still inspect as part of a targeted compliance issue or complaint, but the ABIP certificate provides good peace of mind that you're in substantial compliance.
I also recommend reading the rules themselves. 47 CFR 73.1870 specifies the rules regarding Chief Operators and 73.1800 and 73.1820 specify rules regarding the Station Log. You can also follow the FCC Self-Inspection Checklist.
The big compliance issues are the following:
EAS: Are you monitoring the correct stations as listed in the State Plan? Have you been receiving tests or activity from required monitor sources weekly? If not, you need to research the cause of any missed tests and log the cause. Are you relaying required-relay items? Are you issuing Required Weekly Tests? Any missing activity - either receiving or transmitting - without explanation is cause for a violation. You must have a copy of the current FCC EAS Handbook available at the Primary Control Point.
Public File: This is a whole section on its own. For a non-comm, go through the list in 73.3527 (e). Any missing documents are a violation.
Chief Operator: You must have a written designation of Chief Operator. This goes at the posting point with your station licenses. The Chief Operator is required to review the Station Log weekly and sign and date it. The Station Log does not necessarily have to contain "meter readings" as it used to - though such readings are a part of the Station Log when taken - but you have to review and sign something weekly. Nowadays this is mostly EAS and tower light monitoring.
Antenna Structure Registration: If you own the tower and it's required to be registered, the registration must be correct and the ASRN must be posted as required. Note that the FCC is writing up stations for administrative violations related to ASRNs such as towers showing as "under construction" or an outdated registrant address or phone number.
Tower marking: Your tower lights must be working and paint must be in good condition if required. If you are the tower owner, it is your responsibility. If you are a licensee on the tower, you may be held responsible if the owner doesn't do it. Tower lights must be monitored. Quarterly tower lighting inspections are required.
AM station tower fencing: Effective locked fences are required at any AM tower with potential at the tower base. You must have a key to the fence. Fencing in poor condition, easily bypassed, or too small to prevent access to the tower is a violation.
Main studio rules: Your station must have a main studio located within your community of license, within the primary service contour of any other AM, FM, or TV station with the same community of license, within 25 miles of the reference coordinates of the community of license, or you must have a waiver. The main studio must be staffed by one full-time management-level employee and one part-time employee or more during business hours. You must have a telephone number that is toll-free to the community of license.
Equipment performance measurements: For an FM you must retain your most recent Equipment Performance Measurement for inspection. For an AM you must complete annual NRSC measurements.
RFR: You must comply with standards protecting the general public and workers from excessive Radio Frequency Radiation conditions.
Auxiliary Service licensing: If you are operating any stations in the Broadcast Auxiliary Service (microwave STLs, RPUs, etc.) you must operate those stations in accordance with their authorizations and maintain copies of those authorizations.
FCC rules may be read here: http://www.hallikainen.com/FccRules/2010/73/
If you need assistance with compliance or other technical matters, I am available for such services in New York or New Jersey.
I also recommend reading the rules themselves. 47 CFR 73.1870 specifies the rules regarding Chief Operators and 73.1800 and 73.1820 specify rules regarding the Station Log. You can also follow the FCC Self-Inspection Checklist.
The big compliance issues are the following:
EAS: Are you monitoring the correct stations as listed in the State Plan? Have you been receiving tests or activity from required monitor sources weekly? If not, you need to research the cause of any missed tests and log the cause. Are you relaying required-relay items? Are you issuing Required Weekly Tests? Any missing activity - either receiving or transmitting - without explanation is cause for a violation. You must have a copy of the current FCC EAS Handbook available at the Primary Control Point.
Public File: This is a whole section on its own. For a non-comm, go through the list in 73.3527 (e). Any missing documents are a violation.
Chief Operator: You must have a written designation of Chief Operator. This goes at the posting point with your station licenses. The Chief Operator is required to review the Station Log weekly and sign and date it. The Station Log does not necessarily have to contain "meter readings" as it used to - though such readings are a part of the Station Log when taken - but you have to review and sign something weekly. Nowadays this is mostly EAS and tower light monitoring.
Antenna Structure Registration: If you own the tower and it's required to be registered, the registration must be correct and the ASRN must be posted as required. Note that the FCC is writing up stations for administrative violations related to ASRNs such as towers showing as "under construction" or an outdated registrant address or phone number.
Tower marking: Your tower lights must be working and paint must be in good condition if required. If you are the tower owner, it is your responsibility. If you are a licensee on the tower, you may be held responsible if the owner doesn't do it. Tower lights must be monitored. Quarterly tower lighting inspections are required.
AM station tower fencing: Effective locked fences are required at any AM tower with potential at the tower base. You must have a key to the fence. Fencing in poor condition, easily bypassed, or too small to prevent access to the tower is a violation.
Main studio rules: Your station must have a main studio located within your community of license, within the primary service contour of any other AM, FM, or TV station with the same community of license, within 25 miles of the reference coordinates of the community of license, or you must have a waiver. The main studio must be staffed by one full-time management-level employee and one part-time employee or more during business hours. You must have a telephone number that is toll-free to the community of license.
Equipment performance measurements: For an FM you must retain your most recent Equipment Performance Measurement for inspection. For an AM you must complete annual NRSC measurements.
RFR: You must comply with standards protecting the general public and workers from excessive Radio Frequency Radiation conditions.
Auxiliary Service licensing: If you are operating any stations in the Broadcast Auxiliary Service (microwave STLs, RPUs, etc.) you must operate those stations in accordance with their authorizations and maintain copies of those authorizations.
FCC rules may be read here: http://www.hallikainen.com/FccRules/2010/73/
If you need assistance with compliance or other technical matters, I am available for such services in New York or New Jersey.
B
bilco
Guest
The rules for directional AM's differ depenidng on wehter the sampling system is type accepted (approved?) or whatever. General rule, if it would be legal for unattended operation, it would probably need little in the log other than tower lights, power change times and EAS.
Bilco
Bilco
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