Often-forgotten FCC rules

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The FCC creates and enforces the rules that radio stations live by. Inevitably, it seems that the chief engineer is regarded as the fount of all FCC knowledge.

Long ago, when stations had engineering staffs, a station would have a chief RF engineer and also a chief audio engineer. Talent weren't allowed to touch a disk, and with eight-hour shifts at the transmitter with a complete set of readings taken every half-hour, the chief engineer was an important person.

Keep a current set of FCC rules on hand at every station and familiarize yourself with any changes as they are made.

The station engineer is often the person who prepares applications for filing with the FCC, and who is responsible for the safe keeping and exhibition of licenses and associated FCC material. In small stations the chief engineer should be consulted concerning the compilation of the public information file (PIF) because of his familiarity with the FCC. Responsibility for the compilation of the PIF should not be dumped on the chief engineer alone. The station manager, or his responsible delegate, should work with the chief engineer. Only the station manager or his appointees will be familiar with the actions taken to meet local listening area needs, or complaints concerning programming. Often signal interference letters are mailed to the station but are lost on their way to the engineering department.

Many years ago the Commission's rules were divided into logical groups so that technical and administrative requirements were kept separate. However, now that AM, FM and TV technical rules are interspersed throughout Part 73, it becomes important to read every rule.

When the FCC was formed in 1934, the existing rules inherited from its predecessor, the Federal Radio Commission, were incorporated plus additional rules necessitated by expanded broadcast activity. It seems that the number of rules peaked around the 1970-1980 period. Since then they have been decreasing in the old, original technical area, while adding new technical rules as communications science advances in the more esoteric systems.

In the early days of radio broadcasting equipment tended to be unstable and its continuous performance capabilities were unknown. As a result, it was necessary for the FCC to publish strict, and in many ways confining, rules to ensure efficient operation and prevent interference. Most of the old, restrictive rules have been eased, particularly in the area of AM directional antenna operation. It's interesting to note however, that the original AM frequency stability rule of plus or minus 20Hz has not changed.

The modern rulebook

There are a few former mandatory rules that still have big teeth in them. Rules that once had such stern requirement for weekly or daily inspection and verification, now say that these things should be done as needed. Unfortunately (in the sense of being an essential action), the new rules nearly say “…must be made…” I said unfortunately because lacking a specific directive makes it is easy to overlook such instructions. For example, consider rule 73.1580.

Rule 73.1580 requires that regular inspections be made. No specified interval is prescribed, nor is any method of record keeping indicated. Nevertheless, FCC inspection records will be required. Apart from the legality of making periodic inspections, good engineering practice requires that equipment be inspected and its condition noted. Not only is it a requirement, it becomes a useful piece of information when something breaks down.

Rule 73.1590 covers equipment performance measurements. Most of the old, often complicated, demanding and laborious AM and FM transmitter performance measurements have been deleted. The rule lists the circumstances under which equipment performance measurements have to be made. This rule lists a few circumstances that require equipment performance measurements to be made. As a result, such measurements can be overlooked, even when performing one of the operations listed in the rule.

The Commission has re-examined its tower locating and identifying routine. All licensed towers receive a unique identifying number, which must be displayed legibly and clearly on the fence surrounding the tower. Failure to identify the tower in a manner satisfactory to the FCC inspector results in a stiff fine.

E-mail Battison at batcom@bright.net.

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