By: Mark Croom, Riverfront Communications, LLC
It’s been a privilege to visit broadcast facilities around the state as the Alternate Broadcast Inspection Program representative for the Michigan Association of Broadcasters for the past two calendar years. It’s always interesting to see what kind of shape I’ll find stations in from the compliance standpoint. Here are a few of the common things that I find out of order that you may wish to double-check as you consider the compliance profile of your facility:
EAS System equipment – Your EAS system is required to be monitoring certain signals, and generally I find those to be correct, but occasionally if a radio that doesn’t have fixed tuning gets bumped or its components start to age it may be locked on another station or just picking up noise in between stations. I recommend you turn on the speaker in your EAS unit monthly and listen to each input and make sure it’s on the correct station and the audio is acceptable for retransmission. Your assignments are in the State or applicable Regional EAS Plan. Each week when your log reviews happen (see item #2 below) there should be an entry for each required monitor source, and one for your station or stations that show an EAS test or alert sent.
Station log reviews – It is not true that station logs are not required, though I often find folks who believe this. Logs must contain records of every test or activation of the Emergency Alert System, and any anomalies in your tower lighting system as observed in daily checks or alarms received from the tower lighting controller. Logs are required to be reviewed weekly by the station’s Chief Operator. Interesting item about the tower lights; no entries are required for working systems, but if you’re checking once every 24 hours there’s no reason to not record that fact. Your log should have a signature and date when it’s reviewed, then be filed and kept for two years. You’re also required to investigate any missing but required EAS tests. Have you upgraded your Sage ENDEC since the new Rev95 firmware was released? If you haven’t, you’re not receiving the required CAP/IPAWS tests and those should be noted in the log, with the reason that the firmware update is not yet complete. You should also not put that off any longer!
Quarterly Tower Lighting Inspection – If your station owns its tower, and that tower is required to display obstruction lighting, you are required to do a specific inspection of the lighting system and any associated alarms once a quarter. This should be logged in either the station log at the studio, or in a maintenance log at the tower site.
Missing items in the Online Public File – Sometimes I find required items missing from the Online Public File. You should review with your Counsel any questions you may have about this, but the most common one I find is that the station license isn’t posted correctly. This should be handled automatically by the FCC’s systems, but if you’re a TV station just repacked, or an older AM or FM station (last license before 1980 or so) your license link may pull up a document that says “Authorization not yet created by MB.” This does not absolve you of the requirement to have your license in the file. I suggest you scan the license you have, and place it in the “Additional Documents” section of the station information section of the site, along with the latest renewal if that is also missing. For repacked TV stations, once you have your new license it can take the FCC quite some time to get your authorization updated. I recommend when you get that new license, just upload a PDF to “Additional Documents” so you’re covered.
Issues and Programs lists – These quarterly filings are the bane of many a news director or manager’s existence. The Commission requires us to serve the public interest with our programming, and these lists are how we document what we’re doing. They should begin with a brief narrative, describing the issues being addressed in the list and in a general way the programming that addresses the issues enumerated. After the narrative, there should be a list of entries, either in table or paragraph form, that contain in each entry a specific issue listed above, the name of the program that addressed the issue, and (at a minimum) the date, time, and duration of the segment that addressed the issue. 5-8 of these entries per quarter is generally considered to be adequate, but you can obviously do as many more as you wish, covering things your station actually addressed in its program offerings. These must be uploaded to the online public file within ten days of the end of each calendar quarter (but you knew that part). I often note missing pieces the “at a minimum” section, or no narration in the filed lists.
AM power changes and/or directional parameters off, or monitor equipment faulty – Often when it comes time to check AM stations, I find there’s no way to be sure pattern switches are happening on schedule. This is important for any station with multiple power levels. You need to be sure (and able to demonstrate) that changes are happening on time. If you have a directional, it’s equally important that you’re monitoring directional parameters often enough to know that the system is operating as intended. If for some reason the numbers are off, make sure your antenna monitor is working OK before you start trying to make things work by turning knobs on the phasor. I’ve been in more than one station that had a faulty monitor; once repaired, usually the system falls back into place pretty easily if there’s no major component failures in the phasor or ATUs.
These are the major areas of concern that I find when I’m in the field. If I’ve already been in your station you know the drill. I would encourage all stations to check these items carefully, and make changes if needed before I come to your station to inspect. I look forward to meeting another great group of Michigan broadcasters in 2020.