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Being duly diligent in station operations
I want to address the people in a radio station engineering department who are responsible for ensuring that the station is operating in accordance with the terms of its license. In the past the term “chief engineer” was always meant the head of the engineering department. However, about the time when the technical qualification requirements of personnel operating radio transmitters were reduced and almost eliminated, the FCC introduced a new title: chief operator.
There has never been a mandated FCC requirement for a chief engineer. The term, however, has been in common use since radio stations had large engineering staffs and station management actually realized the value of the work that the engineering department performs. Today, engineering services and costs are regarded as liabilities and rarely appreciated — until the transmitter dumps and commercial revenue ceases. Then the engineer is called in to repair the transmitter.
The chief operator's responsibility is to take responsibility for the station's technical operation. In certain situations, the chief operator must be a full-time employee of the station and cannot be a contract engineer. Outside of that limitation, anyone can be appointed chief operator regardless of technical ability. The important thing is that a memo is published and on file specifying the appointment as chief operator. Often this memo is overlooked and results in a fine.
Let's discuss what a new chief engineer should do on arrival at his new station.
Check the paperwork
Every station has a precious piece of paper called a station license. In many stations, it is hard to find the most current one. The license provides the authorization for the operation of the transmitter and it must be immediately available, either displayed on the wall or filed in an identified and clearly available folder.
The FCC Rules state that the technical data requested by an FCC inspector must be immediately available. Someone at the station must know where the material is and how to get it. The chief engineer is the natural choice for this responsibility, but it inevitably falls to the chief operator.
A person taking over as a chief operator will find a wide range of items that must be checked and operating values that must be kept within limits. This information is contained in the FCC Form 302 (Application for Station License). Additional data is contained the Engineering Report, which forms part of the official application for license.
To protect his integrity, the new chief operator should ask for all licenses and applications that have been filed in connection with the operation. These must be checked against all operating transmitter systems. Don't forget to include STL and RPU licenses with recent FCC rulings and notices. Any discrepancies must be corrected and records made of the action taken. Much of the work involved with station licenses includes voluminous record keeping and the maintenance of paper trails demonstrating efforts to comply with FCC requirements. Time spent doing this will reduce future headaches.
In connection with checking paperwork, make sure that temporary license modifications are not in force. It is not unusual for a station to be authorized to operate at variance from licensed parameters. This usually means that something is awry in the antenna or transmitter system and it is not possible to achieve the licensed values. A notice from the commission is the usual method of notification and authorization. I have found that these are often misplaced or not available when an inspector appears. Special temporary authorizations (STA) are usually handled in the same way, and once again it's important to have paper proof of the commission's approval.
A frequently overlooked item is EAS tests. I've visited too many stations where I have found far too many logs that failed to show reception or transmission of the prescribed test. Worse still, there was no explanation given of the failure to follow the rules and the actions taken to prevent future failures. Often a simple statement such as “new operator, repeated EAS instructions and gave more written instruction” will earn forgiveness from an inspector. Completely ignoring the blank log space, however, can lead to expensive trouble. Time taken on arrival at a new station to go over current logs can often pay good dividends.
Stations must maintain all operating parameters within the limits of the license, especially for AM directional stations. I have found that the best way to start is to ensure that the transmitter and antenna system are operating in accordance with the licensed values, preferably at mean values so that there is room in the control range to take up variations in component values.
When you are satisfied that the antenna base operating impedance or common point impedance is correct, check the antenna base operating current or common point operating current. Do this after adjusting the phasor controls to the licensed operating parameters. When you are satisfied that the system is properly adjusted, take the field strength meter and visit all the official monitor points. If the monitor points fall nicely within limits, you can feel safe that the system is operating as licensed. It is also important to show maximum and minimum legal common point or base operating current in an easily visible and convenient location.
Nondirectional stations rarely have monitor points to check, but there could be exceptions. That's another reason for demanding all engineering and FCC license documentation when taking over a new responsibility. If there are no official designated field strength specification points, one can take informative measurements based on the theoretical service column shown in the original application.
While you're investigating AM field readings, also check that the required NRSC measurements have been made and are on file.
The need to check tower paint colors and the lighting system is obvious. Photo cell operation and flash repetition rate require collaboration and verification, and any special or unusual operating requirements contained in the license should be verified as to being in force.
Station management expects to be able to rely on chief engineers and their staff. If engineering personnel offer information and suggestions to improve operations and the bottom line, management will appreciate the value of competent technical personnel.
E-mail Battison at email@example.com.
Photos by Ben Weiss, CPBE, of KMXV, KCKC, KFKF, and KBEQ, Kansas City.
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