The FCC is stepping up enforcement on pirate radio. They have released an enforcement advisory, which you can read here.
The advisory starts out like this:
WARNING: Unauthorized Radio Broadcasting is Illegal
Persons or Businesses Operating “Pirate” Broadcast Stations
Are in Violation of Federal Law and Subject to Enforcement Action
Okay, so when you stop laughing, here is what will really happen: They will go out, bust a few pirates, issue larger than normal Notices of Apparent Liability, collect none of the money from them and call it a huge success. I doubt very much that the FCC or congress has the wherewithal to wage an all out effort against pirate broadcasting. This is the same FCC that eliminated most of its field enforcement agents and closed most of their field offices. But that doesn’t matter either, because the NYC field office is still open and within a ten mile radius of that, there are likely a dozen or more unlicensed broadcasters.
In the mean time, if you are a licensed broadcaster, God forbid you accidentally miss a Required Monthly Test or have an unlocked tower fence.
It is like the city police force that sits on a stop sign writing tickets to otherwise law abiding motorists when the next block over, kids are out in the street openly selling bricks of heroin. Meanwhile, the chief of police sits in his office furiously typing blistering memos saying that the sale of heroin is illegal.
On June 19th, WKZE received a notice of violation from the FCC’s New York Field office. The crux of the issue seems to be interference being generated on 784.8 MHz (WKZE 8th harmonic) to a new Verizon Wireless installation located nearby:
47 C.F.R. §73.317(a): “FM broadcast stations employing transmitters authorized after January 1, 1960, must maintain the bandwidth occupied by their emissions in accordance with the specification detailed below. FM broadcast stations employing transmitters installed or type accepted before January 1, 1960, must achieve the highest degree of compliance with these specifications practicable with their existing equipment. In either case, should harmful interference to other authorized stations occur, the licensee shall correct the problem promptly or cease operation.” The eighth harmonic of Station WKZE-FM (784.8 MHz) was causing interference to the Verizon Wireless transmitter located approximately 500 feet away.
First off, we note that the WKZE transmitter is not allegedly causing interference to a Verizon Wireless transmitter, but rather to a Verizon Wireless receiver. That may be splitting hairs, however, since the FCC is quoting a technical rules violation, they can at least get the technical language right.
A brief examination of rest of FCC part 73.317 is in order to find the specification cited in section (a). Section (d) states:
(d) Any emission appearing on a frequency removed from the carrier by more than 600 kHz must be attenuated at least 43 + 10 Log10 (Power, in watts) dB below the level of the unmodulated carrier, or 80 dB, whichever is the lesser attenuation.
Since 784.8 MHz – 98.1 MHz is greater than 600 KHz, this is the section that applies to the WKZE situation. Thus, the interfering signal must be greater than -80 dBc to trigger the Notice Of Violation (NOV) from the FCC. The station ERP is 1,800 watts or +62 dBm. Measurements were made with a an Agilent N992A spectrum analyzer using an LPA-1000 log periodic antenna. At a 12 foot distance away from the WKZE transmitter cabinet, the signal on 784.8 MHz was found to be -94 dBc or 0.000063 watt. At the base of the Verizon Wireless tower, the measurement was -124 dBc, or 0.000000025 watt, which is barely perceptible above the -130 dBm noise floor. There does not appear to be any violation of 47 CFR 73.317. Rather, the issue seems to be Verizon Wireless’s deployment of 700 MHz LTE band and the use of high gain antennas coupled with high gain preamplifiers on frequencies that are harmonically related to broadcast stations nearby. In this particular installation, the antenna has 16 dB of gain, minus a 4.5 dB of transmission line loss into a 21 dB preamplifier before the receiver. At the output of the Verizon preamplifier, the signal on 784.8 MHz was measured at -89 dBc, which is still in compliance.
By these measurements, clearly WKZE is not in violation of any FCC regulation. It makes one wonder, does the FCC understand it’s own rules? Or, is this a matter of favoritism towards a huge corporation over a small independent radio broadcaster. Is it a matter of “broadband at the expense of all others?” There are several of these broadcast to 700 MHZ LTE interference cases pending throughout the country. This could set a dangerous precedent for broadcasters and other RF spectrum users as wireless giants like Verizon throw their weight around and eye even more spectrum to press into broadband service.
Commlaw blog has a good post this subject: Harmonic Convergence?
Update: Response from WKZE attorney can be found here, includes the above mentioned actual measurements.
I found this interesting article in Inside Radio: FCC simplifies complaint process.
This is part of the “Reboot FCC” initiative which started many months ago. While I applaud the FCC acknowledgement that they are essentially a slow, plodding government bureaucracy, saying something about it and doing something about it are two different things.
The Consumer Help Center is a website where the public can complain about such things as junk faxes, telemarketers, TELCO billing issues, ISPs, indecent language and a whole host of other topics.
My question is, what happens to the complaint, once it is received? I’d like to hear if anyone has tried this and what the results were. Perhaps they will include a section for reporting IBOC interference on the broadcast band.
I was this interesting tidbit on the Radio World website the other day. The question is, how much authority does the FCC have to conduct a search of a private residence. The Electronic Frontier Foundation wanted to know therefore they sent a FOIA request to the FCC seeking documents supporting this claimed authority.
The documents received seem to be redacted and some are mostly blank, such as the training module on how to obtain permission to enter private property is supposed to take 6 hours to complete, but consists of 3 paragraphs and 2 questions. Hopefully that is redacted and does not reflect on the quality of agents the FCC is employing these days. The upshot seems to be the agent either needs a warrant or permission.
It may be surprising to some citizens, however, the FCC does have the authority to investigate radio signals, whether they are intentionally generated, as in a pirate broadcaster, or unintentionally generated, as in a piece of gear gone bad.
According to federal regulations, an FCC agent may request entry to inspect a private building anytime he/she believes there may be a device emitting radio frequency energy. This includes anything with a FCC part 15 sticker, which can be computers, TV remote controls, garage door openers, WiFi network routers, etc. This basically covers every house in the US as well as most businesses. Those rules were written when most homes and businesses did not have any RF generating devices and there was little to indicate that they ever would.
Consequences for failure to allow an FCC field agent into a residence or business appears to be the issuance of a citation in the form of a threatening letter. Continued intransigence would be met with a NAL (Notice of Apparent Liability) followed by a forfeiture notice also known as a fine. The typical FCC fine these days seems to be $10,000.00. If it is a repeated and willful violation, equipment can be ceased and the perpetrator arrested.
In instances where safety of life is in question, then every step necessary to disable the offending device needs to be taken. Things like transmitters spurring into aircraft frequencies or TV antenna amplifiers running wide open, also interfering with aircraft frequencies comes to mind.
One of the examples given details a field agent trying to track down a noisy cable TV amplifier. From the FCC field agent’s perspective, the homeowner appears to be a royal pain in the ass. In this day and age when everything has a computer and most of them generate RF, tracking down interference can be a painstaking process, especially where housing is dense. Uncooperative home owners, especially dumb ones, who have no idea what they have plugged in only make things worse.
Still, there is the issue of forth amendment rights, which, if the above law was misinterpreted, misused or applied with the wrong standard would likely be trampled. In these days of extra constitutional activity, giving Los Federales an entry into one’s house might invite unwanted scrutiny by other agencies. As far as changing the rules, with the current group of scoundrels and rouges in the legislative branch, one might end up with something ten times worse than before.
FCC fines to broadcasters is nothing new. Broadcasters have often tried to cut corners, hiring incompetent staff that cannot be bothered to report tower light outages, or simply not monitoring tower lights at all. Untrained operators who do not know the EAS rules, sloppy public files, unattended main studios, over power operation, etc. Some AM stations have power changes as sunset and sunrise, most are now automated but who is checking the automation system to make sure the power changes?
The FCC does not have nearly enough field agents to monitor everything. Most rules infractions never get discovered, like the translator operating at double its licensed power. Or the FM station with the antenna at the wrong height on the tower. It never ends. When I first got into this business, I remember one FCC inspector that was going to issue a NOV (Notice of Violation) because the operator signed her name in red ink. RED INK, by god! It seems things have swung far in the other direction.
Fortunately for us, these infractions become public record, so we can all learn from other’s mistakes, right?
Here is the current crop of FCC fines being shuffled through the bureaucracy:
Clarion County Broadcasting Corp. the licensee of radio station WKQW in Oil City, Pennsylvania, apparently willfully and repeatedly violated Section 73.1745(a) of the Commission’s Rules by operating at times beyond the station’s post-sunset authorization. Clarion is liable for a forfeiture in the amount of four thousand dollars ($4,000.00). To determine whether WKQW was operating consistent with its authorization, an agent from the Philadelphia Office installed radio monitoring equipment in Oil City, Pennsylvania to record, on a continuous basis, the relative signal strength of WKQW’s transmission on the frequency 1120 KHz. The equipment was in place from October 28, 2008 to December 12, 2008.The agent reviewed and analyzed the radio transmission data recorded between October 28, 2008 and December 12, 2008, and found several violations. The agent determined that, between October 28, 2008, and October 30, 2008, the station operated after 8:30 p.m. local time, which is the end of the station’s post-sunset authorization during the month of October. The agent also determined from the recorded radio transmission data that, between November 1, 2008 and November 13, 2008 and between November 15, 2008 and November 25, 2008, the station operated past 7:00 p.m. local time, which is the end of the station’s post sunset authorization during the month of November. In response to an inquiry from Commission staff, the owner of Clarion confirmed that the station’s transmitter did not malfunction during the period between October 28, 2008 and December 12, 2008.
I find it interesting that the FCC has some sort of remote monitoring device that it can install and monitor an AM stations power levels. I wonder where they installed it. I also have to wonder what it looks like. Is it an outdoor unit, like something one might see attached to a utility pole, or an indoor unit, stashed away in an office somewhere. Very curious, indeed. If I were the station owner, I might ask to see the records that the automated recording device created. That would seem to be a reasonable request.
Caron Broadcasting, Inc. licensee of station WKAT, in North Miami, Florida, apparently willfully and repeatedly violated Sections 73.1745(a) and 73.3526 of the Commission’s Rules by operating at times with power other than those specified in its license and failing to maintain and make available a complete public inspection file. Caron is liable for a forfeiture in the amount of eight thousand dollars ($8,000). We also admonish Caron for the failure of the station’s chief operator to review, sign and date the station logs on a weekly basis as required under Section 73.1870(c)(3) of the Rules.On January, 26, 2009, an agent from the Miami Office monitored WKAT’s transmissions from approximately 5:00 p.m. until 7:00 p.m. The agent made several field strength measurements of the station’s signal and observed no reduction in the transmissions’ field strength after sunset.On January, 27, 2009, an agent from the Miami Office monitored WKAT’s transmissions from approximately 5:25 p.m. until 6:45 p.m. The agent made several field strength measurements of WKAT’s signal and observed no reduction in the transmissions’ field strength after sunset. At 6:43 p.m., the agent made a field strength measurement of the station’s signal one block from the WKAT studio.
On February 5, 2009, at 11:01 a.m., an agent from the Miami Office made a field strength measurement of the station’s signal one block from WKAT’s main studio, which measured approximately the same level as the nighttime measurement that was made there on January 27, again indicating that WKAT was not reducing its power at night. The agent immediately conducted an inspection of WKAT’s main studio with the station’s general manager and designated chief operator. The chief operator stated that the station uses a remote phone monitoring system, which allows the caller to change from day mode (mode “2”) tonight mode (mode “1”). At 11:55 a.m., the chief operator called the transmitter using the remote monitoring system, which indicated that the daytime mode transmitter power was 4,758 watts. At the request of the agent, the chief operator switched the transmitter to nighttime mode, and the system indicated that the power was 316 watts. At 1:45 p.m., with the WKAT transmitter in nighttime mode, the agent made a field strength measurement near the WKAT studio which was much lower than the daytime mode measurement made earlier that day. This measurement confirmed that the station’s transmitter and transmitter remote control system were functioning properly.
Still on February 5, 2009, the agent inspected WKAT’s available daily transmitter logs, which showed that from December 4, 2008 until February 4, 2009, WKAT was not reducing power at night as required by its license. All the log entries made during the daytime and nighttime were in the range of approximately 4,600 to 4,900 watts, and indicated that the transmitter was in mode “2,” the day mode, at all times. The log entries for the early morning hours of February 5, 2009 indicated that WKAT was operating at nighttime power at that time. Neither the station manager nor the chief operator could explain why the power was not being reduced, or why or how the situation was corrected early that morning. The agent also found that none of the station logs were signed by the chief operator or by anyone else. There was apparently no verification of whether or not the station was operating with authorized power, and no initiation of any corrective action for the overpower condition that had been ongoing for several months. The agent also requested to inspect the station’s public inspection file and found that it did not contain the quarterly radio issues/programs lists for the 1st through 4th quarters of 2008. The station manager stated that he did not know where the issues/programs lists were, but that they may be in storage since WKAT moved its studio in August 2008.
They tracked that one down the old fashioned way, multiple visits at sunset to take field strength meter readings. It seems like no one at this radio group knew anything about FCC requirements and rules. None of this is rocket science, really. These NAL’s are both over a year old. I wonder why it is taking the FCC so long to get through this process?
I recently got into an argument about the requirements for transmitter readings with a fellow engineer. Said fellow stated that transmitter readings need to be taken every three hours and that all operators needed to sign on and off the station log. Time was when those things were supposed to be done, that is true. I believe the rules have changed a little bit since he last read them. The current FCC rules (part 73.1820) state that the following items need to be in the station log:
- Tower light malfunctions and repairs
- Emergency Alert System (EAS) tests and activations
- AM antenna field strength measurements (73.61) (monitor points)
- Calibration of remote control equipment
- Equipment performance measurements (frequency, harmonics, spurious emissions, etc) (73.1590)
- Each entry must be signed
- The logs are to be reviewed and signed by the chief operator
The exception to this is AM stations without an FCC approved antenna sampling system, which indeed require readings on the antenna system every three hours. Most AM stations have an approved antenna sampling system.
If an AM station has an approved sampling system, it will be noted on the instrument of authorization (license).
For transmitter operations, a review of part 73.1350 shows that the licensees are responsible for insuring transmitting apparatus complies with all FCC regulations. Specifically:
73.1350 (b)(2)(c)The licensee must establish monitoring procedures and schedules for the station and the indicating instruments employed must comply with Sec. 73.1215.
73.1350 (b)(2)(c)(1) Monitoring procedures and schedules must enable the licensee to determine compliance with Sec. 73.1560 regarding operating power and AM station mode of operation, Sec. 73.1570 regarding modulation levels, and, where applicable, Sec. 73.1213 regarding antenna tower lighting, and Sec. 73.69 regarding the parameters of an AM directional antenna system.
One would assume that would mean some sort of logging. Further, a review of all recent NAL, NOV and citations from the FCC’s enforcement bureau shows that field agents investigating a radio station will make their own power measurements if they suspect a broadcast station is operating out of power tolerance. Most particularly with AM directional stations that are supposed to reduce power at night. I doubt very much that producing an operating log with in tolerance power readings would do any good in those circumstances.
For directional AM stations that change power/mode at night, some routine of checking the transmitter for proper power levels after power/pattern change needs to be established. If there is an auto logging system, such as a Burk Autopilot, then checking that system for proper time of day and/or proper pattern/power change functioning could take the place of checking the actual transmitter readings as long as there were an alarm (and notification) generated during an out of tolerance condition.
For most FM stations and AM non-directional stations, most modern transmitters have Automatic Power Control (APC) built in. As long as the APC is functioning properly and there is an alarm (with notification) generated when an out of tolerance condition occurs (under/over power), logging power output readings can be done on a weekly maintenance log.
Station logs are to be retained for two years (73.1840) and should be available to the FCC for inspection. After two years, throw the logs out because anything that you have on file is liable to be inspected. Any rules infractions found in the station logs can lead to a NOV or NAL, even if it happened more than two years ago.
For your reading pleasure:
Sec. 73.1820 Station log.
(a) Entries must be made in the station log either manually by a
person designated by the licensee who is in actual charge of the
transmitting apparatus, or by automatic devices meeting the requirements of paragraph (b) of this section. Indications of operating parameters that are required to be logged must be logged prior to any adjustment of the equipment. Where adjustments are made to restore parameters to their proper operating values, the corrected indications must be logged and accompanied, if any parameter deviation was beyond a prescribed tolerance, by a notation describing the nature of the corrective action. Indications of all parameters whose values are affected by the modulation of the carrier must be read without modulation. The actual time of observation must be included in each log entry. The following information must be entered:
(1) All stations. (i) Entries required by Sec. 17.49 of this
chapter concerning any observed or otherwise known extinguishment or improper functioning of a tower light:
(A) The nature of such extinguishment or improper functioning.
(B) The date and time the extinguishment or improper operation was observed or otherwise noted.
(C) The date, time and nature of adjustments, repairs or
(ii) Any entries not specifically required in this section, but
required by the instrument of authorization or elsewhere in this part.
(iii) An entry of each test and activation of the Emergency Alert
System (EAS) pursuant to the requirement of part 11 of this chapter and the EAS Operating Handbook. Stations may keep EAS data in a special EAS log which shall be maintained at a convenient
location; however, this log is considered a part of the station log.
(2) Directional AM stations without an FCC-approved antenna sampling system (See Sec. 73.68). (i) An entry at the beginning of operations in each mode of operation, and thereafter at intervals not exceeding 3 hours, of the following (actual readings observed prior to making any adjustments to the equipment and an indication of any corrections to restore parameters to normal operating values):
(A) Common point current.
(B) When the operating power is determined by the indirect method, the efficiency factor F and either the product of the final amplifier input voltage and current or the calculated antenna input power. See Sec. 73.51(e).
(C) Antenna monitor phase or phase deviation indications.
(D) Antenna monitor sample currents, current ratios, or ratio
(ii) Entries required by Sec. 73.61 performed in accordance with the schedule specified therein.
(iii) Entries of the results of calibration of automatic logging
devices (see paragraph (b) of this section) or indicating instruments
(see Sec. 73.67), whenever performed.
(b) Automatic devices accurately calibrated and with appropriate
time, date and circuit functions may be utilized to record entries in
the station log Provided:
(1) The recording devices do not affect the operation of circuits or
accuracy of indicating instruments of the equipment being recorded;
(2) The recording devices have an accuracy equivalent to the
accuracy of the indicating instruments;
(3) The calibration is checked against the original indicators as
often as necessary to ensure recording accuracy;
(4) In the event of failure or malfunctioning of the automatic
equipment, the person designated by the licensee as being responsible for the log small make the required entries in the log manually at that time;
(5) The indicating equipment conforms to the requirements of Sec. 73.1215 (Indicating instruments–specifications) except that the scales need not exceed 5 cm (2 inches) in length. Arbitrary scales may not be used.
(c) In preparing the station log, original data may be recorded in
rough form and later transcribed into the log.
Sec. 73.1350 Transmission system operation.
(a) Each licensee is responsible for maintaining and operating its
broadcast station in a manner which complies with the technical rules
set forth elsewhere in this part and in accordance with the terms of the station authorization.
(b) The licensee must designate a chief operator in accordance with Sec. 73.1870. The licensee may designate one or more technically competent persons to adjust the transmitter operating parameters for compliance with the technical rules and the station authorization.
(1) Persons so authorized by the licensee may make such adjustments directly at the transmitter site or by using control equipment at an off-site location.
(2) The transmitter control personnel must have the capability to
turn the transmitter off at all times. If the personnel are at a remote
location, the control system must provide this capability continuously
or must include an alternate method of acquiring control that can
satisfy the requirement of paragraph (e) of this section that operation
be terminated within three minutes.
(c)The licensee must establish monitoring procedures and schedules for the station and the indicating instruments employed must comply with Sec. 73.1215.
(1) Monitoring procedures and schedules must enable the licensee to determine compliance with Sec. 73.1560 regarding operating power and AM station mode of operation, Sec. 73.1570 regarding modulation levels, and, where applicable, Sec. 73.1213 regarding antenna tower lighting, and Sec. 73.69 regarding the parameters of an AM directional antenna system.
(2) Monitoring equipment must be periodically calibrated so as to
provide reliable indications of transmitter operating parameters with a
known degree of accuracy. Errors inherent in monitoring equipment and the calibration procedure must be taken into account when adjusting operating parameters to ensure that the limits imposed by the technical rules and the station authorization are not exceeded.
(d) In the event that a broadcast station is operating in a manner
that is not in compliance with the applicable technical rules set forth
elsewhere in this part or the terms of the station authorization, and
the condition is not listed in paragraph (e) or (f) of this section,
broadcast operation must be terminated within three hours unless antenna input power is reduced sufficiently to eliminate any excess radiation. Examples of conditions that require termination of operation within three hours include excessive power, excessive modulation or the emission of spurious signals that do not result in harmful interference.
(e) If a broadcast station is operating in a manner that poses a
threat to life or property or that is likely to significantly disrupt
the operation of other stations, immediate corrective action is
required. In such cases, operation must be terminated within three
minutes unless antenna input power is reduced sufficiently to eliminate any excess radiation. Examples of conditions that require immediate corrective action include the emission of spurious signals that cause harmful interference, any mode of operation not specified by the station license for the pertinent time of day, or operation substantially at variance from the authorized radiation pattern.
(f) If a broadcast station is operating in a manner that is not in
compliance with one of the following technical rules, operation may
continue if the station complies with relevant alternative provisions in
the specified rule section.
(1) AM directional antenna system tolerances, see Sec. 73.62;
(2) AM directional antenna monitoring points, see Sec. 73.158;
(3) TV visual waveform, see Sec. 73.691(b);
(4) Reduced power operation, see Sec. 73.1560(d);
(5) Reduced modulation level, see Sec. 73.1570(a);
(6) Emergency antennas, see Sec. 73.1680.
(g) The transmission system must be maintained and inspected in
accordance with Sec. 73.1580.
(h) Whenever a transmission system control point is established at a location other than the main studio or transmitter, a letter of
notification of that location must be sent to the FCC in Washington, DC, Attention: Audio Division (radio) or Video Division (television), Media Bureau, within 3 days of the initial use of that point. The letter
should include a list of all control points in use, for clarity. This
notification is not required if responsible station personnel can be
contacted at the transmitter or studio site during hours of operation.
(i) The licensee must ensure that the station is operated in
compliance with Part 11 of this chapter, the rules governing the
Emergency Alert System (EAS).
So 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:
- 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.
- 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.
- 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.
- Equipment performance measurements. These are needed on all AM stations every year. They are carrier frequency harmonic measurements and NRSC-2 mask compliance measurements.
- 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.
You can download the .pdf version here.
Emergency warning siren station
EAS, or more properly, the Emergency Alert System, is a government mandated system of encoders and decoders designed by the federal government to alert the public in case of war or other emergency. It, and it’s predecessor, EBS (Emergency Broadcast System) have never been activated by the federal government. Both systems, however, are used extensively by local and state governments for things like weather alerts, amber alerts, etc.
Back in the mid-90’s the FCC had a chance to redo the EBS and produce something that was a streamlined and effective tool for public warning. Unfortunately, the EAS system is neither. Rather, it is a cumbersome system of weekly and monthly tests scheduled around pre-conceived notions that how the system is tested every week will be how the system works in an emergency. In practice, this is generally a good theory of system design, but it has failed miserably with EAS. The reasons why are thus:
- Most all emergencies are local or at most state wide events. To this day, very few state and or local government emergency managers would be able to activate EAS for their area. The reason is there is minimal if any interface with the LP-1 EAS stations or station personnel. Ignorance and apathy on behalf of both radio station personnel and government officials is the main culprit.
- Most stations are un-maned for large portions of the day. Even if government official could/did call the station, chances are, nobody would be there. If by chance, arrangements were made to contact station employees at home, they would have to interface with the EAS equipment remotely, which ads complexity to an already complex system.
- EAS messages are still mainly relayed from radio station to radio station, the so called daisy chain net work that has been shown numerous times to be unreliable.
- The system of SAME codes, FIPS identifiers is not necessarily bad, the application in this case leaves something to be desired. The FCC had a chance to update EAS before the HDTV rollout. One would assume that any improvements could have been built into the new TV sets that are now being sold, but again, that opportunity was missed. For example, I suggested that each TV have a set up screen option where the owner could input their zip code. They could also choose what types of alerts they would want to know about and even base the alerts types on the time of day. Live in a flood zone, the FFW (Flash Flood Warning) 24/7. Live in tornado alley, TOR (Tornado Warning), etc. The cable companies then pipe in the local NOAA all hazards radio station. All the sudden there is a real national alert system in place using mostly non-broadcast wireless systems. Add to that the ability to sign up for emergency e-mails and text messages for specific areas (many places are currently doing this) and there is multiple message paths.
The system as is is not reliable and sooner or later that will be shown with a large scale failure. Recently, the FCC held a summit with the Department of Homeland Security. The cliff notes version of this event is: Yes, the system can be made better. Let’s keep throwing the same ideas at the wall and see if anything sticks this time. Excuse me if I don’t do back flips, this is the same information that was discussed during the last “lets revamp EAS” discussion back in 2005 (04-296).
In the mean time, the EAS continues to be a good fund raiser for the FCC enforcement bureau. Which, you know, it is easier to go to a licensed radio station and bust them for not re-transmitting the RMT (Required Monthly Test) than it is to go out and bust some of the numerous pirate radio operators, some of whom are operating in the same city/metropolitan area as a field office.
The shame of it is, it could work without a great deal of cost, very well.