by Harold Hallikainen

San Luis Obispo, CA Jim McDonald of Wind River Broadcast Center (phone 303 669 3442) sent me a copy of a two page "Broadcast Station - Self Inspection" issued by the Denver office of the FCC. This form takes the form of a checklist of various items to check along with the associated rule section. Send me a SASE if you want a copy of this checklist.

Wind River is also preparing a custom "Big Book" for stations. This book is an "instruction book" for the station. It includes details on the operation, maintenance and troubleshooting of the studio equipment (how to get back on the air NOW). It also contains the station logs, equipment performance measurements, transmitter (and remote control) operating instructions, etc. The idea is that everything required to operate the station and satisfy the FCC is in this book. During an FCC inspection, the BOOK is turned over, answering all questions. It is, of course, necessary to have operators actually read the book and know what the instructions mean.

Additional volumes of the book include the FCC regulations and the Public Inspection File.

This looks like an interesting project. I'd expect other consultants and contract engineers to also offer similar services. It's more than just fixing what's broken or answering specific questions the station manager may have. It's what I imagine the FCC had in mind for the designated chief operator. The chief operator should insure that the numerous FCC requirements are being met. If the chief operator does not wish to get involved in the public inspection file, program and issues lists, ownership reports, EEO reports, etc., he/she should insure that SOMEONE is indeed fulfilling these responsibilities (and knows what the responsibilities are). The chief operator is often the one ready reference station employees have on FCC rules.

More FCC Self Inspection
In December, we left off our discussion of the FCC's proposed self inspection form with the review of the public inspection file. If you'd like a copy of the 20 page FCC self inspection report, send $2.00 (for copying to H&F, 141 Suburban Road, Building E4, San Luis Obispo, CA 93401-7590) and an SASE (8.5 x 11 inches) envelope ($0.98 postage).

Station Logs
The FCC report concentrates on tower light logging. This and EBS are the only REQUIRED routine entries for most stations. In order to demonstrate compliance with other rules, however, I'd suggest stations continue to operate under the "old rules" which required operator signatures when going on duty and again when going off duty (demonstrating the required licensed operator was on duty) and regular recording of various transmitter parameters. These parameters are typically those required to determine the power by the direct and indirect methods (although FM stations determining power by the indirect method were not required to log a direct power reading) and antenna monitor indications for directional AM stations. It would appear that any documentation you can generate that shows the station operates in compliance the vast majority of the time, AND is frequently checking its operation to insure compliance, would be helpful during an inspection.

The self inspection report asks "What method is used to check your antenna tower lights for outages and how are outages recorded?" 17.47 requires an inspection of tower lights at least every 24 hours. That inspection may be made visually or by an indicator that registers "any failure of such lights". Can your operators determine that a steady burning side light has failed? As an alternative to daily inspection, 17.47 allows the use of an automatic alarm that provides an indication of the failure of any lamp to the station licensee. Finally, 17.49 requires any tower light failures and repairs to be logged in the station log.

The FAA must be notified of the failure of any top lamp or any flashing side lamp. The FAA need not be notified of the failure of steady burning side lamps, though such failures need to be logged and repaired as soon as possible. "If a tower light outage has occurred in the last year, please send a photocopy of the log and label it as Attachment B." The form then asks for the date of the last tower lighting inspection, as required by 17.47(b). This section requires an inspection at intervals not exceeding three months of all automatic or mechanical control devices, indicators and alarm systems associated with the tower lighting. Does the photodetector turn the lamps on and off at the proper illumination levels (lights on when the north sky illuminance on a vertical surface falls to 376.74 lux, or before; off when the north sky illuminance on a vertical surface increases to 624.31 lux or later)? Is the beacon flash rate correct (12 to 40 flashes per minute)? Can the operator detect the failure of any one lamp? Has the FAA been contacted within the past year regarding tower light outages? Which FAA facility is normally notified? This information (which facility, phone number, etc.) should be part of the printed operator instructions available at the control point. I'd suggest the notification of the FAA be logged in the station log, along with the name (or other identification) of the person at the FAA notified.

Next Month
The next section of the FCC Self Inspection form covers EBS. I get calls from many stations trying to "get around" the various EBS requirements when using "nontraditional control points". This section of the FCC form anticipates many of the problems people are having complying with EBS requirements when there is no one at the station program control point (the studio) who can instantly respond to EBS alerts (receive the alerts, put required announcements, tones and programming on the air). In general, if you are proposing anything unusual, I'd suggest getting a letter from the FCC in Washington approving your proposal or granting a waiver of appropriate sections of the rules. In addition, some transmitter operating services (such as National Supervisory Network) have gone to considerable effort to insure their services comply precisely with FCC requirements ("comply the EBS rules instead of getting around them"). I'll look forward to your comments.