Living with the FCC - a History

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The well-known engineering consulting firm of Silliman, Moffat and Kowalsky also operated a very useful printing company named Seabrooke Printing, which was invaluable to the consulting engineers in the Washington, DC, area. They supplied matts of the FCC forms at very reasonable prices and produced excellent printed applications ready for filing with the Commission.

It seems that for a long time the preparation and delivery to the FCC of Form 302 was a major factor in the industry. However as time has passed and new services have been developed the volume of applications received by the FCC has increased tremendously. Over the years some forms and applications have been deleted. The Special Temporary Authorization (STA) still does not require a form. But it is often a very important part of engineering work. This term was sometimes confused with the now obsolete Special Service Authorization (SSA).

The SSA was an amazing piece of legal legerdemain. It must have been devised by lawyers because it allowed something to be done that was completely prohibited by the rules. As its name implies it was an authorization for special broadcast service presumably based on special needs.

I first came across an SSA as an intern with Jansky and Bailey in 1946. WNYC had an SSA. When I joined ABC's engineering staff SSA's became of great interest to me because we operated WJZ in New York on 770kc as a 1A station and KOB Albuquerque full-time with 50kW was also on 770kc as a 1A station! Operation of a second station on a class 1A frequency was strictly forbidden by the rules. I can't remember the excuse given by the legal eagles for the issue of these two 1A grants on the same frequency but they covered their mistakes by issuing an SSA to KOB. SSA's were usually good for six months at a time. So for a very long time KOB existed on a series of SSA's. When the United States decided to actively participate in the CCIR Region 2 regulations the station class designations and powers changed and it seems to me that the WJZ/KOB confrontation was conveniently lost in the shuffle.

Mention of Region 2 brings to mind the memory of the four days in 1991 when the United States had a 9kc channel separation in the AM medium waveband. This occurred at the commencement of the 1981 World Administrative Radio Conference in Buenos Aires. To a certain extent the broadcasting industry had become concerned with the possibility of interference mainly through heterodynes from emerging nations as the powers of their transmitters increased. The 9kc separation used in other parts of the world meant that there was a strong probability of 1kc heterodynes occurring on many of our AM medium-wave channels. In my opinion also there was a possible hidden benefit for hungry potential broadcasters in the change from 10kc to 9kc separation because this could mean the possibility of more medium-wave AM stations in the United States.

The US/FCC delegation flew down to Argentina with orders from the FCC that our separation was then 9kc and we were to persuade the conference to agree to 9kc separation for the Americas. By Wednesday evening of that week we had persuaded the conference to agree. On Thursday morning we received instructions from the commission to revert to 10kc separation! Sanity had prevailed. So we then had to reverse all the reasons we had given for using 9kc and persuade the conference to return to 10kc. Fortunately, we were able to do so, and Region 2 reverted to the status quo. Thus ended 9kc separation for the AM band in the US.

With the passage of years Commission operations have changed. We once had to file an increasing amount of paper work. Today the Commission appears to abhor paper and now insists on receiving applications via e-mail. And it almost seems as though paper work is no longer in style. How tempus fugit!

E-mail Battison at

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