fcc – Page 13 – Engineering Radio

Transmitter readings

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 ensuring 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.

And

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. 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 the 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 rule infractions found in the station logs can lead to an NOV or NAL, even if it happened more than two years ago.

For your reading pleasure:
73.1820

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
replacements made.
(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
deviation indications.
(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.

73.1350:

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).

FCC inspections for broadcast stations

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 as 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 AIPs 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 checklist that is downloadable from the FCC website. 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 an EAS test. Make sure that all the EAS logs have been checked 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 are within 3 percent of licensed values. All monitor points below the 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 downloaded 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, I 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, and 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 checklist that an FCC inspector will use if he is inspecting a broadcast station.

You can download the .pdf version here.

About community radio

Because of this post, I have received some e-mails 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 the 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 overcrowding the FM band with more and more small signals will degrade it. There are no ifs, and, 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 sideband 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 sideband 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 of 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, for 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 yourself. I, on the other hand, would like to avoid the AMization of the FM band.

That is all.

Local Community Radio Act (HR 1147/S 592)

I sent off a letter to my Senators and Congressman this morning regarding HR 1147/S 592 AKA Local Community Radio Act. Basically, I am against this. Not that I don’t appreciate what it is trying to accomplish. I believe the technical degradation of the FM band is a higher concern. After all, if we turn the FM band into what the AM band has become, nobody will listen to the radio.

Radio is too important to ruin. Here is what I wrote:

I strongly urge you NOT to support the bipartisan Local Community Radio Act (HR 1147/ S. 592) sponsored by Reps. Mike Doyle and Lee Terry and Sens. Maria Cantwell and John McCain.

In spite of what many have said, Low Power FM (LPFM) contributes to the technical degradation of the FM service. By adding more and more signals covering every possible spot in the FM spectrum, the noise floor is raised causing many FM receivers to “picket fence” which is annoying to most listeners.

Radio has suffered enough degradation over the last few decades. AM radio is now so fraught with interference, especially at night, most people do not even consider listening to it. Packing the FM dial with thousands of low power operators will create the same problems and cause most people to abandon radio altogether.

I am a strong proponent of 1st amendment rights. I believe the sponsors of this bill are well intentioned, however misinformed. I believe that the deregulation of commercial radio allowing one company to own 1,200 radio licenses has created most of the problems we see today.

Clear Channel, in particular, has removed almost all localism from radio, creating bland canned music channels. Their modus operandi was to buy a group of radio stations in a market, combine the stations under one roof, get rid of most of the staff, and drop the advertising rates so other local stations could not compete. Non-Clear Channel stations were then forced to make cuts in there advertising rates and or expenses to stay in business.

The answer is not to create a bigger mess. Instead:

1. Push the FCC to tighten ownership rules. In some ways the horse is already out of the barn, but it would prevent another Clear Channel from forming in the future.
2. If major radio groups go bankrupt and are broken up, allow it to happen, do not intervene. This will allow real radio broadcasters to pick up the pieces and put something together. Perhaps investigate supporting small radio owners by waiving FCC fees and limited tax breaks for a period of time.
3. Push the FCC to continue with the localism hearings they were conducting.
4. Push the FCC to update the EAS and make a workable Emergency Alert System in the US.

Radio is too important a resource to have it ruined. Of all the media outlets, radio is the most robust. During an emergency often times the utility grid is down. Many radio stations have backup power generators and can provide vital information when the internet, phone system, cable TV network, cellphone system, e-mail, etc are down.

Radio can provide local government important mass access to their constituents during elections and at other important times. Radio is free, there are no subscription fees, no service providers, etc. Almost everyone owns a radio, most people own several.

Small savvy radio owners can make a go of it, provided the deck is not stacked against them.

Please DO NOT support the Local Community Radio Act. Thank you.

If you want to get involved, you can go to the Free Press website, there you will find a link to a “Take Action” page (not sure that link will work). Again, I am not opposed to Free Press or even Free Radio. Packing the FM spectrum with LPFM, translators and the like will only create reception problems. This is just become another reason for people not to listen to radio.