FCC inspections for broadcast stations

FCC-AltLogoSo here you are, minding your own business on a not so frantic Wednesday afternoon, when a guy shows up in the lobby and wants to see you.  The receptionist says he has a badge and he is from the FCC.

Oh no! Panic! Mayhem! Chaos! Etc!

Actually, things are not so bad as they might seem, after all, this is not your father’s FCC.

Many stations use the state broadcaster associations Alternative Inspection Programs (AIP).  This is where you pay a contractor from the broadcaster’s association to come out and do a mock inspection of your radio stations.  After the station “passes” the “inspection” it is issued a “certificate” that “insures” it won’t be inspected by the FCC for three years.

Totally bogus, or as the French might say, complete bull shit.

The stations I currently work for had those “certificates.”  When the FCC inspector showed up, he laughed at them and inspected us anyway.  We complained to the state broadcasters association and the head of the FCC enforcement bureau at the local field office, all to no avail.   This happened four times.  Each time the FCC inspectors found nothing and went on their way.

What did I learn from this?  Why bother with the stupid AIP’s when all that needs to be done is comply with the FCC’s rules.  After all, the so called “inspector” from the broadcaster’s association is merely going to use the same FCC check list that is down loadable from the FCC web site.  Anyone can do that themselves.

I also learned that the FCC inspectors check a few things more closely than others.  For example:

  1. The public inspection file should be perfect.  Since they inspect these stations all the time, they know what is usually missing; Issues and quarterly reports, Contour maps and license renewal cards.
  2. EAS logs and procedures.  Make sure that every operator knows how to send and EAS test.  Make sure that all the EAS logs have been check and signed by the chief operator.  Make sure that any discrepancies are noted.
  3. Directional AM station operating parameters.  Still a hot button issue and one area that trips up a lot of people.  All antenna parameters within 3 percent of licensed values.  All monitor points below maximum allowed.
  4. Equipment performance measurements.  These are needed on all AM stations every year.  They are carrier frequency harmonic measurements and NRSC-2 mask compliance measurements.
  5. Tower fences and tower registration numbers.  Big one and easy to spot and fix.  All AM towers need to have a locked fence around the base insulator.  Any tower over 200 feet tall needs to be registered and have a sign with the registration number posted.  The sign needs to be accessible and legible.

So prepare ahead of time for the inevitable visit.  It is very easy to comply with the FCC rules using the FCC checklists.  Both the AM station checklist and the FM station checklist can be down loaded and used to self inspect any radio station.

Here is something else that I have found.  Clean up the transmitter site.  Sweep the floor, replace the burned out lights, empty the garbage, keep a neat maintenance log, etc.  These things go a long way to making a good first impression, which can make the inspection go a lot better.

Once, myself and the FCC inspector pulled up in front of the transmitter building of an AM station.  The grass in front was mowed, the bushes were all trimmed back, the field was mowed, the towers had new paint on them, The fences were in good shape, the place just looked good.  We were about to go inside when he asked “Does the inside of that place look as good as the outside?”  Which it did and I said yes.  Then he said he had seen enough, have a nice day.

So, when the FCC guy shows up, offer him a cup of coffee and relax, things are going to be alright.

Update: This is the actual check list that an FCC inspector will use if he is inspecting a broadcast station.

FCC_Inspection_Checklist

You can download the .pdf version here.

About community radio

Because of this post, I have received some e-mail asking why I am against community radio.  I am not.  In fact, I support community radio.  I think that community radio done well is a wonderful tool in our democracy, giving a voice to those that are watching government.  It also promotes other locals interests, events, music, etc.    I would like to see more failing stations bought by community broadcasters and turned into something that is a public trust and responsive to the local population.

What I was trying to get at in the previous post was that over crowding the FM band with more and more small signals will degrade it.  There is no ifs, ands or buts, removing third adjacent protections on the FM band will increase the noise floor.  This will lead to more interference on the average FM radio, which will lead to more people getting fed up and tuning out.

Here is why:  You cannot change the laws of physics.  FM transmitters have output filters that attenuate side band energy, that is to say, energy transmitted on 1st, 2nd and 3rd adjacent channels.  A 50,000 watt FM station on 100.3 MHz will have side band energy on 100.1, 99.9 and 99.7 MHz as well as 100.5, 100.7 and 100.9 MHz.  Due to the limitations on the components used to construct those filters, they can only be designed with the accuracy of the components used.  In other words, most electrical components have a tolerance given in percent, example +/- 10%.  That means that the value of the component will change, usually because of heating.  Therefore, output filters cannot be constructed to limit emissions to only the main channel and say one adjacent channel, they would drift off frequency.

Also, creating a brick wall filter that cuts everything off at the second adjacent channel will cause distortion of the RF signal on the main channel.  With analog AM and FM transmitters it cannot be done.  Digital transmissions are another story, but that is not what we are talking about here.

That is an engineer’s point of view.

One other thing about adding hundreds more LP FM signals.  There should be something that stipulates most (say >50%) of the programming be locally originated.  Recorded for later playback is fine.  Having thousands of LP stations broadcasting the same syndicated shows or running voice tracked automation 24/7 would be a recreation of the AM band as it currently exists.  If you want to listen to that, then it already exists, help your self.  I, on the other hand, would like to avoid the AMization of the FM band.

That is all.

Working with Tower Companies

Almost all radio stations use a tower of some sort to support their transmitting antennas.  These towers need maintenance from time to time and only qualified people should perform maintenance on towers.  Hence, the tower company is formed.

405 foot guyed tower with ERI FM antennas
405 foot guyed tower with ERI FM antennas

Over my years of experience, I have dealt with many different tower companies, from one man operations to big corporations that have multiple crews out in the field on any given day.  I have discovered that not all tower companies are created equal.  Not only do tower climbers need to be in good physical shape and be trained correctly in all tower climbing safety procedures,  they also need to be good mechanics so they can actually repair things on the tower.   Climbing a 470 foot tower to repair a strobe light is all well and good.  Once the climber gets to the strobe light, he needs to be able to disassemble it without dropping parts or breaking things, trouble shoot if needed, install new parts and re-assemble the unit, again without dropping or breaking anything.

Applying a RF connectors, installing a FM antenna or STL antenna, repairing light fixtures or conduit all require some amount of manual dexterity and concentration.  Assembling high powered antenna requires close attention to detail.  Any pinched O rings, cross threaded bolts, bent bullets and the antenna will have problems, likely at the worst possible time.

The sign of a bad tower company is if it’s climbers cannot carry out those tasks with one or at most two climbs.  I have a situation on a tower where our FM station is a tenant.  The tower has a strobe light failure near the top of the tower where our FM antenna is located.  They have climbed the tower no less than four times to repair this, and it is still not fixed yet.  Each time they climb, the station has  to reduce power to protect the tower climbers from excessive RF exposure.  Each climb it takes them several hours longer than anticipated to finish their work.

A good rule of thumb, If the defective part cannot fixed in the first two climbs, then the entire strobe unit should be replaced on the third climb.  Even though the strobe units are expensive, by the time they get done paying for all this tower work, they could have bought two new strobes.  Today will be the fifth climb and there is no guarantee that it will be fixed.

I advised the tower owner that they should be looking around for another tower company because these guys aren’t exactly setting the world on fire.

If it ain’t broke, break it

One thing that I find a little annoying is the continuing need to reboot everything at some interval.  Computers in the studio, audio vault servers and work stations, e-mail servers, files servers, network routers, and so on.  Got a problem, first thing to do is cycle the power off and on…

One of the most irritating pieces of equipment is the audio processors on one of our FM stations.  A few years ago, we purchased the whiz bang Omnia 6 processor.  Every 6 or 8 months the thing losses its mind and sounds terrible.  The station gets all bassy and the high end sounds distorted.  I have tried everything I can think of to prevent this, including installing an UPS, extra grounding, extra shielding, software updates, etc.  In the end, it just has to be rebooted, which of course, means several seconds of dead air.  Naturally, this processor is at the FM transmitter site, where it is difficult to get to.

Truth be told, when it is working, it does sound pretty good on the air, but is it $10,000 dollars better than the older Optimod 8100A?  No, it is not.

The old Orban Optimods sound pretty good as long as they are re-capped and aligned every so often.  If fact, our number one billing station has an AC format and uses an Optimod 8100A and nothing else.  Our other station in the same market uses an Optimod 8100A and a pair of Texar Audio Prisms. In the ten years I have been working for this group of radio stations, I have never had to reboot the Optimod or the Audio Prisms, they just seem to work continuously without problems. Imagine that.

I have seen this called a “retro audio chain” by some.  Nothing retro about it, a little care and feeding and I’d stack this equipment up against an Omnia 6 any day of the week and twice on Sunday.

This is a grainy video of an 8100A  in action:

That was taken in our rack room using off air audio on the rack room speakers and a cheap video camera. You get the idea.

So here is to Frank Foti and his marketing gurus that have sold all of the program directors in America on the need to “update” there air chain processors, because, you know, the Optimod, that is old skool.