What is the FCC likely to be looking for when it’s eying a station for an inspection? Attorney David Oxenford recently offered some tips on things that the FCC might be considering that might at the same time slip beneath the radar of station management.
For starters, in his Broadcast Law Blog, Oxenford mentioned the “alternate broadcast inspection program” offered by the Kansas Broadcasters Association – a good opportunity to see how your station will fare in the event of an actual FCC inspection.
Oxenford also mentions the two infractions that frequently wind up resulting in financial penalties. One involves the public inspection file – he mentions the most frequent failure there, lack of all the necessary issues/programs lists. The other area that frequently results in fines is EAS – broadcasters should be sure that this equipment is in good condition at all times.
Two areas that may slip below the radar are studio-transmitter links (STLs) and Remote Pickups (RPUs). These auxiliary signals move content between a station’s studio and transmitter or from a remote location, they use spectrum themselves, and they require a license. Using unlicensed links can result in the same kind of fines people get for operating pirate stations.
Another potential problem is operating them from a location other than that for which they are licensed. It’s important to make sure the operations are legal and are properly situated.
Another thing stations need to be cognizant of is the existence of a “chief operator.” The identity of this person needs to be readily available, in writing, along with the license of the station. It can be a contract engineer at many stations, but for AM stations with 10 kW of power or more, or a directional array, or TV stations, the chief operator must be a full-time station employee.
Safety is a primary FCC concern, says Oxenford, and therefore towers are a primary inspection target. Proper painting, lighting and enclosures are a must.
The other big thing is to never do anything that results in a specific complaint made to the FCC by a third party – of course, there’s only so much an operator can do about that.