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The rules we live by - TvTechnology

The rules we live by

Let us all humbly face the center part of the East Coast of these United States and quietly acknowledge the home of our exalted leader, the Federal Communications
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Let us all humbly face the center part of the East Coast of these United States and quietly acknowledge the home of our exalted leader, the Federal Communications Commission. From the un-ivied halls of that great institution, via the government printing office, are regularly issued those guidelines with which we, as broadcasters, must comply. We normally refer to those guidelines as the Rules and Regulations in all of their various parts, chapters and volumes.

Every station should have a complete and up-to-date set of the applicable sections of the rules on hand. In a pinch, the rules are available in a hopefully current condition via the FCC webpage at www.fcc.gov. A nice, time-consuming and frustrating search of that page should result in one being able to find any particular rule of concern. That really doesn't replace an on-site set of the rules. At least parts 73 and 74 should be maintained.

Part 73 contains the basic rules for radio broadcast services. That includes full-service AM, FM, non-commercial FM and television operations.

Part 74 covers auxiliary services including low-power television, STLs, intercity microwave and related areas. If a really complete set of the rules is desired, include what is normally referred to as Volumes 1 and 2.

The rules change often and with no real notice. Unless one either reads the Congressional Record every day (lots of luck) or carefully checks the FCC Daily Digest, rule changes will be missed. However, there is a solution.

There are Washington firms that offer the rules for purchase and provide updates to the rules on a regular basis. Such a service is offered by the venerable and respected Pike and Fisher (800-255-8131), Rules Service Company (301-424-9402) and others. It is possible to bring the station files fully into the modern era by buying the rules on disk. For example, the author subscribes to a service that sends updated rules monthly on disk, along with a program to access the rules in a mysterious and confusing fashion. Once the rules are safely established in a computer, they can be reviewed in a fashion that consumes much more time than if they were on paper. That same service provides hard copy sets of the rules that are updated on a somewhat regular basis by sending the pages containing changes for insertion into loose-leaf binders. The normal routine is to look for the rules on the computer until frustration reaches a level that sends the user either to the printed version of the rules or to the nearest source of behavior modification (like in a black, square bottle.) In reality, the computer version is very handy for checking on a quick point. The paper version is better when studying a significant problem in detail.

As to the rules themselves, broadcasters have been lulled into a false sense of security by the so-called deregulation process. For example, the rules used to contain lengthy and detailed requirements for devices used to maintain a transmitter's operating frequency. Older technicians will remember when the rules even specified the acceptable range of temperature to be maintained in crystal ovens. In addition, frequency monitors were required to be type accepted with their own strict set of operating requirements. All of that is gone, along with even the requirement for frequency monitors. That really makes sense, as low cost frequency counters are readily available to check a station's frequency that offer far more than the necessary stability and accuracy. However, the lack of regulation concerning the frequency controlling devices and those for frequency measurement has tended to mislead the broadcaster.

There has been no relaxation on the tolerances for operating frequencies. The relaxation has simply given the broadcaster the option of determining the manner in which he will maintain the station operation within those tolerances. If the Commission checks a station when their monitoring truck is in the area and finds the frequency out of tolerance, notification will be made and an appropriate fine will be assessed. The operating requirement is still there - only the manner in which that requirement is met has been opened to the broadcaster's method of choice. If the frequency counter the chief engineer bought at the ham fest and which he has never bothered to check for accuracy has led to the station being 1kHz beyond the allowable error, the fine will still be assessed.

A similar situation applies to the station logs and other records. For years, the rules specified various parameters that had to be measured and logged. Those logs were required to be maintained for at least two years and made available to the Commission upon request. Now, the logs that have to be maintained only have to contain the record of the tower lights, Emergency Alert System operations and a few other special requirements (Check 73.1820). That has not eliminated the need to maintain power with its associated measurement. It has only eliminated the need to write the information down. Most quality operations still maintain a complete log with regular meter readings. That is still in accordance with good operating practice - it just isn't required by the rules.

Equipment performance measurements that used to be required on a periodic basis are now only required for new installations or "as needed" to maintain operation within the rules. The station is allowed to determine when such measurements are "needed," but will feel the full wrath of the Commission if found not to be in compliance when inspected or monitored.

The Commission is still very testy concerning the public reference file. The requirements in that regard are still rigidly defined and contained in great detail in the rules (See Sec. 73.3527). If the chief engineer does nothing else to comply with the regulations, he should at least check the file against the rules to determine that all required documents are included. That includes, in part, a copy of all licenses and applications. It isn't brain surgery to keep a complete public file, but it is totally unacceptable to allow the file to be incomplete. The public file is one issue where the Commission is adamant concerning the contents, and where the fine will be significant if a station is careless.

One more little point: On the logs for the tower lights and EAS operations, if something is done wrong (such as transmitting an EAS test warning of a tidal wave in Boise) log it the way it happened and leave it alone with the fond hope that no one will ever notice. You only have to worry for two years and then you can destroy it and breathe easy. The station would be exposed to a much greater level of punishment if the log were found to misrepresent actual events. The old adage "Hell hath no fury..." doesn't really apply today. A woman scorned doesn't compare to the action of the Commission if it finds that someone blatantly lied on an official document. That would include the station's logs. If someone screwed up, let the admission of that error exist in the appropriate files - don't try to cover it up with a second error.