So, You Want To Be An ‘Alternative’ FCC Inspector?

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Of all of the jobs available in the United States of America, does “independent alternative broadcast media inspector” pique your interest? If so, this column from Media Information Bureau featured columnist Ken Benner and his wife, Karen, who are veteran alternative broadcast inspectors, is just for you.


Ken and Karen offer their suggestions on how new inspectors can best conduct themselves, provided in good faith and without compensation to assist both radio and TV stations to achieve assurance of FCC regulatory compliance.


By Ken and Karen Benner

This column was not intended to solicit additional clients. This column was written to simply explain items that we have, for years, used to assist the transparency, clarification and simplifications of FCC compliance.

One item we have frequently been questioned about is how we can conduct inspection certifications without actually being on site for a station. This method came about when it became obvious that the very substantial costs surrounding travel, lodging, office costs, photocopies, etc., could be avoided, especially when air travel is necessary.

A station requesting certification is mailed a double-sided “inspection report” specific for their type of station — the same as used for an on-site visit.  One side covers a description of the major items of FCC compliance concern along with the related regulation number, with an underlined space for the initials of the station engineer, manager, Public File custodian, and such, certifying compliance or an understanding to achieve compliance.

The inspection is then conducted by telephone.

For example:

________Public File is compliant (§73.3526, §73,3527, etc.) 

________Power 90-105% as authorized, (§73.1560)

________Direct and Indirect Power agree (TSA & §73.1560)

________EAS Encoder-decoder FCC certified (§11.34(a))

The reverse side of this report is identical for all types of stations and includes a 10-item “Broadcast Antenna Tower Survey” (FCC File 1130-A as modified).

Following that are spaces for the Inspection Participants to provide their “Initials, Signature, Title and Date” for their participation.

The final item provides a statement for compliance and/or non-compliance (indicating items “Pending” with an explanation to address such items within a limited period of time (usually 30 to 60 days) for minor items and serious items a means utilizing a notarized acknowledged statement for corrections.

For potential independent inspectors I suggest the following items for your serious consideration:

Before promoting yourself as an inspector, it is essential to develop some degree of professional certified accreditation, such as a college degree, FCC license such as the “General Radiotelephone Operator License,” Society of Broadcast Engineers’ level of achievement, International Association of Radio Telecommunications Engineer, or an IEEE level of membership.  Such is to illustrate your level of education and experience.

Before conducting any inspection be certain to obtain an indemnification statement clearly stating the inspection is being conducted in good faith with the best ability for all involved and is signed by the inspector, each station staffer, manager, engineer, public file custodian, contract engineer or anyone else with any degree of the inspection participation.  Responsibility is thus shared.

Another item I consider very important for myself and anyone I work with or co-signs any certificate under my seal is a clearly defined Code of Ethics. My code has appeared in a previous column and is available upon request. I urge new comers to make use of it.

It was a mandated violation of my professional code that prompted me to sever my relationship with a “coordinator” and his group of the original “Mock inspection team”  several years ago.

Absolute integrity is essential for any one in a position to conduct compliance certifications for broadcast operations in many cases valued in the millions of dollars.

 

Ken Benner is an independent Alternative FCC Compliance Certification Inspector and a research analyst for the Coalition for Transparency, Clarification and Simplification of Regulations pertaining to American Broadcasting. Benner has more than 55 years of experience providing service to the broadcast industry.

The views expressed by Media Information Bureau columnists are those of the writer only and not of the editorial board of the Radio + Television Business Report or its parent, Streamline Publishing.

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