Self-Inspection Checklists · 11/15/2010 2 Why are the checklists important? The checklist is...

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Self-Inspection Checklists

Dennis BaldridgePresenter

Why are the checklists important?

The Enforcement Bureau (EB) of the FCC is committed to improving licensee compliance with the broadcast regulations.

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Understanding the FCC's Self-Inspection Checklists

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The enforcement effort usually involves an on-scene station inspection conducted by FCC personnel.

Most on-scene inspections are conducted without prior notification to the station licensee.

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Why are the checklists important?

The checklist is designed to assist broadcast managers in conducting a self-inspection of their station.

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It provides the opportunity to review and correct any deficiencies.

Where do I find the checklists?


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http://www.fcc.gov/eb/bc-chklsts/

Important Notes!

Not all broadcast regulations are covered by the checklists!

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Represents Substantial Compliance

Have the checklist in one hand and the FCC rules in the other hand (available online).

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Each question has two or three possible responses


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No is not an acceptable response to the FCC

NO = Violation

FCC Rules are cited throughout the document


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Are you ready to be inspected?


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Each checklist is divided into several sections

Administrative and Non-Technical

AntennaStructures

EmergencyAlert System

(EAS)


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Technical

AttendedVS

UnattendedOperation

LocalMarketing

Agreements(LMA)

Abbreviations Glossary of Broadcast Terms

AM Directional Stations

Other areas include:


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NOTE: Some questions need to be updated. EX: Television Modulation, etc

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station license construction permit renewal certificate (associated with authorization)

auxiliary transmitter authorizationspecial temporary authorization (STA)

SECTION I: ADMINISTRATIVE AND NON-TECHNICAL AUTHORIZATIONS


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special temporary authorization (STA) and any other authorization

readily available and easily accessible at the station's principal control point

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equipment status/calibration

Emergency Alert System (EAS)

tower light outages

SECTION I: ADMINISTRATIVE AND NON-TECHNICAL STATION LOGS/RECORDS


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tower light outages

chief operator designations

equipment performance measurements

kept in an orderly and legible manner

suitable form and with sufficient detail

logs and records are to be retained for a period of two years, unless specified (AM stations need th l NRSC t t )


(cont.)


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the annual NRSC tests)

made available for inspection or duplication at the request of the FCC


(cont.)


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Who is the Chief Operator?


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Each station must designate a chief operator – in writing and posted with the station authorization

Agreements with chief operators serving on a

SECTION I: ADMINISTRATIVE AND NON-TECHNICAL CHIEF OPERATORS


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contract basis must be in writing

Review the station logs at least weekly

Required entries are being made correctly

SIGN AND DATE the log upon review

Inspection and calibration of the transmission system, monitors, metering and control systems in addition to any equipment performance

SECTION I: ADMINISTRATIVE AND NON-TECHNICAL CHIEF OPERATORS (cont.)


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y q p pmeasurements or other tests as specified in the rules or terms of station authorization

An electronic signature is acceptable in station logs and records which are maintained on digital media

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SECTION I: ADMINISTRATIVE AND NON-TECHNICAL CHIEF OPERATORS (cont.)


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What is a legal ID?


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At the beginning and ending of each period of operation and hourly as close to the hour as feasible, at a natural break

Legal ID = Station's call letters immediately followed by the community of license

SECTION I: ADMINISTRATIVE AND NON-TECHNICAL STATION IDENTIFICATION


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Any reference to additional communities must be made after the community of license

The licensee, frequency, channel number, or both, may be inserted between the call letters and community of license

No other insertion is permissible

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SECTION I: ADMINISTRATIVE AND NON-TECHNICAL STATION IDENTIFICATION


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SECTION I: ADMINISTRATIVE AND NON-TECHNICAL TELEPHONE ACCESS TO STATION


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SECTION I: ADMINISTRATIVE AND NON-TECHNICAL PUBLIC INSPECTION FILE

PIF available for public inspection at any time during regular business hours = generally any eight hour period between the hours of 8 a.m. and 6 p.m., M-F


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Licensee may require members of the public to provide personal information as a prerequisite to granting access to the public file: limited to the name and address of the person(s) seeking access to the file


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May be maintained in a computer database as long as the computer terminal is made available to members of the public who wish to review it.


If you don't have one – set up a file with hanging file folders

Label a folder for each of the topics pertaining


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Label a folder for each of the topics pertaining to your station. Order not specified but recommend placing it in order of the checklist

If a folder is empty, you may wish to notate that it does not apply to your station at this time



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What is a Citizen Agreement?

It is an agreement between a licensee and one or more citizens that deal with goals or proposed practices that affect station operations in the public interest in areas such as - but not limited to -


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interest in areas such as but not limited to programming and employments

These agreements shall be retained for the term of the agreement, including any renewal or extensions


Service Contour Maps, submitted with any application

Showing service contours

Main studio and transmitter location (State,


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( ,county, city, street address, or other identifying information).

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Ownership Report and supplemental reports

Corp. - By-laws, Articles of Inc.

Partnership partnership agreement


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Partnership – partnership agreement –Typically, an LLC does not have By-laws

May remove proprietary or confidential items


Ownership - cont.


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EEO Report in PIF

Small station exemption - fewer than five full-time employees

Check rules for details


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Check rules for details

And on WEB site


A copy of the most recent version of the manual entitled "The Public and Broadcasting" must be present in the PIF. (current version 2008)

St ti t id th t


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Stations are to provide the current version of this Manual free of charge if requested (see Manual)

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Letters in the Public File – save for 3 years!

E-mails computer or paper


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FCC Investigations or complaints

Investigation or complaint to the FCC of which the applicant, permittee, or licensee has been advised


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licensee has been advised

Retained until notified in writing that the material may be discarded.


Issues and Programs

List of programs that have provided the station's most significant treatment of community issues


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community issues

Filed Quarterly

Includes a brief narrative

Minimum of time, date, duration & title

Retained until next renewal is final

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Commercial Limits

No commercial television broadcast station licensee shall air more than 10.5 minutes of commercial matter per hour during children's programming on weekends, or more than 12


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minutes of commercial matter per hour on weekdays


Children's Programming

Form 398


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Donor Lists

For Non-commercial stations

Save for 2 years


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Local Announcements

A statement certifying compliance with this requirement.

The dates and times that the pre filing


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The dates and times that the pre-filing and post-filing notices were broadcast and the text.

The certifying statement shall be retained in the public file for the period specified in § 73.3580 (for as long as the application to which it refers).



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Must Carry Election

For Commercial Stations

Retained for 3 years election period


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Questions about the PIF


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Main Studio Presence

Allows the licensee to make the station available for inspection at any time during normal business hours


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Normal hours are typically an 8 hour period between 8:00 a.m. and 6:00 p.m. local time M-F

This requirement is separate from the unattended transmitter operation rules


Main Studio Location Within principle contour

Within 25 miles of reference center


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See FCC rules for other options

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SECTION II: ANTENNA STRUCTURESTopics Covered

Antenna Registration

Antenna Specifics

Tower Light Observations


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Painting/Lighting

FAA Notifications

Station Logs

SECTION II: ANTENNA STRUCTURESAntenna Registration


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SECTION II: ANTENNA STRUCTURESAntenna Specifics


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SECTION II: ANTENNA STRUCTURESTower Light Observations

Check Lights at least every 24 hours

Quarterly Tower Light Inspection

Tower Renters may share some responsibility if a problem occurs!


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responsibility if a problem occurs!

SECTION II: ANTENNA STRUCTURESPainting/Lighting

One of the most common problems associated with tower painting is the feedlines that are on the outside legs of a tower. The solid black colored feedlines may defeat the purpose of the painting by covering up the outside legs of the


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painting by covering up the outside legs of the tower.

SECTION II: ANTENNA STRUCTURESFAA NOTIFICATIONS – HOW LONG DO I HAVE?

The tower owner/licensee is to notify the FAA within 30 minutes of the observation of an improper functioning or extinguished top steady burning light or ANY flashing obstruction light regardless of its position on


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the structure.

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SECTION II: ANTENNA STRUCTURESFAA NOTIFICATIONS – HOW LONG DO I HAVE?

Such improper functioning beacons include non-lighted beacons as well as those that are lighted, but non-flashing.

N tifi ti i t l b d i di t l t


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Notification is to also be made immediately to the FAA once it is returned to service.

FAA Phone: 877-487-6867 (for NOTAM)

SECTION II: ANTENNA STRUCTURESLOGS must contain the following

The nature of such extinguishment or improper functioning

The date and time the extinguishment or improper operation was observed or otherwise noted

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Date and time of FAA notification, required for outages of any flashing light, NOTAM

The date, time and nature of adjustments, repairs or replacements made. This would include any work conducted as part of a system inspection or preventive maintenance program

SECTION II: ANTENNA STRUCTURESLOGS (cont.)

Log quarterly inspections of lighting systems


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Is your EAS working?


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SECTION III: EMERGENCY ALERT SYSTEM (EAS) Q 70 - 85

PARTICIPATING vs. NON-PARTICIPATING

Current EAS Handbook at EACH normal duty operator position

Certified Equipment & Status (monitor and


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q p (Generator)

Automatic & Manual operation = staff altered

Monitoring the stations assigned in State EAS plan

SECTION III: EMERGENCY ALERT SYSTEM (EAS) (cont.)

Does the station send RWT at random days and times?

RMT each month: receive and send

RWT each week from each of its two


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RWT each week from each of its two assigned monitoring sources?

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SECTION III: EMERGENCY ALERT SYSTEM (EAS) Station Logs

EAS logs maintained?

Any failures notated?

Equipment outages notated?


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Request Extension if more than 60 days

SECTION IV: TECHNICAL REQUIREMENTS

Updates needed to accommodate new forms of transmission: 8-VSB, IBOC etc.

Operating Power Q86

Does the License specify TOP if so is it still correct?


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If not, you need the calculations for TOP – Antenna Gain, feed-line loss, combiners, filters

Direct vs. Indirect measurements: power calibration Q87

Frequency Q88

SECTION IV: TECHNICAL REQUIREMENTS(cont.)

Modulation Q89

Remote Control Q90-91

Functioning

Metering: readings & calibration


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Emission Limits Q92

Monitoring Schedule Q93

Periodic Calibration Q94

Logging of adjustments Q95

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SECTION V: ATTENDED VS UNATTENDED OPERATION

Attended = live person on duty 24/7

Unattended = automated remote control

FCC rules specify time requirements

U tt d d t t b f d ith i


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Unattended not to be confused with main studio presence

SECTION V: ATTENDED VS UNATTENDED OPERATION

Alternate Control Point

Other than main studio or transmitter

Applies to Attended operation

Notification letter in station records


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Notification letter in station records

SECTION VI: LOCAL MARKETING AGREEMENT (LMA)

If you have an LMA then you will need Q 100-

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Copy of agreement sent to FCC and in file

List of all contracts in effect


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List of all contracts in effect

Licensee maintain control

Licensee must maintain managerial staff at the station

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SECTION VII: AM DIRECTIONAL STATIONS

Field Strength – are all monitor points at or below the maximum values specified in the authorization? Q101 AM

Are the monitor points documented


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Are the monitor points documented correctly in the authorization? Q102 AM

Is approved monitor and metering in use Q103 -104 AM

SECTION VII: AM DIRECTIONAL STATIONS (cont.)

Directional Parameters – do current ratios (5%) and phases (3°) match the authorization

At variance for 10 days w/p FCC approval


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At variance for 10 days w/p FCC approval then must request STA – reduce power if necessary

Logged?

SECTION VII: AM DIRECTIONAL STATIONS (cont.)

Most recent field strength measurements available?

Most recent partial directional antenna


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Most recent partial directional antenna proof readily available?

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The FCC, Media Bureau, Audio Division maintains a web page at "http://www.fcc.gov/mb/audio".

Current rules pertaining to AM and FM stations are maintained at ""

Where can I get further help?


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are maintained at .

Information on EEO requirements for broadcasters are maintained at http://www.fcc.gov/mb/policy/eeo or by calling EEO staff at (202)418-1450.

Hopefully at the end of any real, self or mock inspection you will get a well done handshake.


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Credits


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Q & A


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Self-Inspection Checklists · 11/15/2010 2 Why are the checklists important? The checklist is...

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