FCC Inspection Doesn’t Have to be a Painful Experience
by Tim McCartney
Geographically isolated from nearby cities, Boise, Idaho, was frequently chosen to test a variety of consumer products. The closest large market, Salt Lake City, provides 335 miles over which to minimize “advertising interference” from radio and TV stations. And, visits from the Federal Communications Commission (FCC) to inspect radio and TV stations were understandably infrequent.
One such visit occurred by an inspector from the FCC’s Field Operations Bureau in Seattle, located over 500 miles from Boise. The last such FM and TV inspections in this mountain/desert community had been four years earlier, although inspections of cable TV and AM radio facilities had occurred in the interim.
Before visiting any station in Boise, the inspector had already studied all of the local TV and FM broadcast signals using monitoring equipment in an FCC field van and had noted the obvious discrepancies. Two photographic “maps” from the spectrum analyzer examined the entire FM band. The photos were taken at two separate locations one about 30 miles outside of Boise and the other inside city limits.
So, this monitoring meant that the inspector knew a lot, but not everything, about the performance of these transmission plants.
When an FCC inspector is in town, word travels very quickly. But, in the case of the station to be inspected, it was a true surprise. The unexpected am. arrival at the studios opened with an introduction and identification which included a badge, clearly setting the tone for an official visit.
For this particular broadcast facility, such a visit was uneasy, The station was reached him of the increase in power. And, the 3500 feet increase in transmission elevation turned out to be less than everyday discussion among FCC personnel in Seattle.
This experience demonstrated that the regional FCC inspector does not always have current information from the Washington, D.C. offices. While the information was available via computer, it was usually easier to review station documents during inspections and discuss them with station officials.
Despite the surprise, this station was pleased to have the opportunity to demonstrate compliance with FCC requirements. So, here are summaries of the inspections studio and transmitter.
Studio Inspection EBS
The station was asked to produce two weeks of logs which showed the sending and receiving of Emergency Broadcast System (EBS) tests. The inspector said that he usually asks for the last month’s logs. If the recent logs appear in compliance, he asks for no more. However, is problems surface, the last three to six months of logs may be reviewed.
He noted the EBS test receive times from the designated EBS origination radio station in Boise so as to enable subsequent comparisons with logs from other local stations.
Then, he asked the on-ajr operator to conduct an EBS test, in order to ascertain if the operator had been properly trained. Also, he was then able to determine that the equipment was functional and if the two tones comprising the attention oriented EBS sound sufficiently modulated the transmitter so that listeners could readily hear the sound.
He also asked to see the FCC supplied authenticator envelope, which contain authentication words to be verified in case of an emergency.
The FCC inspector explained since FCC deregulation in the 1980’s, many stations incorrectly assumed that EBS requirements were less stringent. He also pointed out that the station must conduct an investigation if even one weak passes during which an EBS test has not been received and logged.
So, the station was asked to show how the logs with EBS entries were being checked each week. This was the mechanism by which stations would log their investigations into EBS problems; Is the equipment malfunctioning? Are the tests being done but not logged? Are the tests not being sent by the primary station?
At least one station in Boise was cited for a six-month failure to maintain a functional EBS receiver. In such cases, FCC Field Operations Bureaus were required to issue a fine. However, the inspector said he would not issue such a mandatory for an occasional mistake.
If a station missed one week’s of logging, there would be no fine. However, he indicated that if a station’s` EBS apparatus was not operational at the time of the inspection and its nonfunctional status not so logged, a fine was certain.
The station was asked to produce from its required public file the “Public and Broadcasting” manual, the most recent station license renewal and the last two community issues/programs in response summarizations.
The FCC required that the April-May-June issues/programs reports be filed by July l0. Since his visit was just four days after this deadline, it was a joyful moment to find the report in the file as required. While the visit to Boise was not planned with this deadline in mind, surprise inspections always pose situations of this type.
Current FCC Authorizations
The inspector asked to see the FCC station license (in this case, a construction permit and license) and the operator licenses. He asked the on-air operator to point out his restricted operator permit.
The station engineer explained how the remote control worked. This system controls the transmitter from the studio site, such as turning the transmitter on/ off, raising/lowering power, and taking remote meter readings.
He observed while the on-air operator called the transmitter and took readings. He studied the instructions posted next to the remote control point with various headings: Sign-On, Sign-Off, How to Put the Transmitter Back on the Air, etc.
At this stage, the inspector asked how the station could be certain that 100% of its FCC-authorized transmitter power was actually being transmitted. The station engineer explained that the transmitter power output was set up and calibrated to the authorized level, which equaled 100% as demonstrated on the transmitter power meter and simultaneously on the studio remote control power meter.
Modulation With SCAs
The inspector observed the levels on the station’s frequency-agile studio monitor. Then, he asked to see two other Boise FM stations which he had already noted where exceeding their authorized modulation levels. As it turned out, the studio monitor agreed with the results noted on the equipment in the FCC van. Since each of these two stations had two subcarriers (SCAs, he said they should reach only 110% modulation. With no subcarriers, 100% was the maximum authorized level).
He indicated that modulation levels were commonly misunderstood. Just how much modulation was allowed with a given number of subcarriers confused many broadcasters. A typical, proper level would be a stereo FM station using subcarriers at' 67 KHz SCA with 10% pilot injection, for a modulation of 110%.
Two rules on SCA injection levels were checked. The rule was that the total of all SCA injections must be 20% or less. The second rule was that those SCAs greater than 75 KHz cannot exceed 10% injected.
The inspector indicated that many stations were unclear on how to measure their SCA injection levels under SCA modulation conditions. He, too, had this difficulty in his remote monitoring van. So, he checked to establish that the total modulation limit was not to exceed. If the limit were exceeded, then he looked in the baseband for a reason.
Frequently, the inspector finds that stations have designated a chief operator who cannot address the issues raised during inspections. Since this person must understand all of the various requirements, ignorance would place the station at considerable risk.
Upon completion of the studio inspection, arrangements were made for a visit to the transmitter site at Boise-area mountain top for the following week. Usually in an inspection, the transmitter site was visited immediately after the studio.
All stations on the mountain were to be represented: FMS in the morning, TVs in the afternoon.
This issue turned out to need resolution. Most of the 13 users on one tower learned that their FCC licenses required that the tower they use to be painted the usual orange and white. But, this tower was not painted at all.
Subsequent discussions turned up the possibility that the Federal Aviation Administration (FAA) might exempt stations on the tower from the painting requirement. Since four painted towers closely located on the mountain top surrounded the unpainted tower, the FAA was contacted in an effort to see if this was an acceptable situation.
The question of responsibility of the required, daily tower light checks also surfaced. While one user on the tower assumed the responsibility, no formal agreement of this arrangement had ever been made.
These tower lighting and painting requirements actually reach beyond the FCC and FAA, to the U.S. Forest Service, which was charged to manage the mountain site. So, a can of bureaucratic worms was opened.
Each station’s antenna was compared to the authorization descriptions on their station construction permit or licenses. Since there were so many FM antennas on this tower, the inspector asked that this station’s be pointed out.
The inspector wrote down three primary transmitter readings: plate volts, current and power forwarded. He then asked for verification of the remote control readings of these parameters.
The on-air operator at the studio then took meter readings and called back to read them directly to the inspector. The plate voltage reading was a little off, but well within the required 2% tolerance. The other two were accurate.
The inspector asked how Transmitter Power Output (TPO) was determined on the basis of the construction permit authorization, which was noted only in Effective Radiated Power (ERP).
He was shown a copy of the computer program results for these calculations, which began with the ERP figure and worked backwards factoring in antenna power gain and line loss to arrive at TPO.
In addition, an in-line power wattmeter and dummy load mounted above the transmitter were also used for power level calibrations.
As it turned out, the required ground radiation standards were not being enforced by the FCC. Rather, such responsibility fell under the auspices of the Environmental Protection Agency (EPA).
This was confusing, since the FCC certainly addressed ground radiation standards in its licensing and renewal process. But, these standards were not enforced by FCC regional field offices.
When asked about the proposed limited-attention overnight operation of the station, the inspector explained that such authorizations came from the policy branch of the FCC. Thus, the role was to ensure that stations comply with the terms of their FCC licenses, not to evaluate the quality of those terms. So, the field offices became involved in' interpretation and enforcement, but not in policy-making. The lesson, then, was that the station authorization (license) needed to spell out critical information as much as possible. If in doubt, approval should be sought from the policy makers So that the inevitable FCC inspection can examine current, accurate authorizations.
I’m from the Government and I’m here to help you. True or False?
Well, this visit was certainly one in which most Boise broadcasters answered m. The visit seized the attention of station management to areas of concern by their own engineering departments. It cleaned up modulation levels. It began discussions on tower lighting and painting. And, it served to remind everyone of easily overlooked FCC regulations.
And, then there was the matter of attitude. Did the FCC inspector relish his power and wave it around? Or, did the inspector treat broadcasters as colleagues? In Boise, even those cited for violations felt they were treated fairly.
Because of government cut backs and deregulation, some thought that remotely-located Boise would be forgotten by the FCC Field Operations Bureau. Since then, with the FCC’s interest established and considerable consumer test marketing underway, will locals there still have to spell and pronounce Boise for everyone east of the Mississippi?