Often-forgotten FCC rules

February 1, 2003

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

Long ago, when stations had engineering staffs, a station would havea chief RF engineer and also a chief audio engineer. Talent weren'tallowed to touch a disk, and with eight-hour shifts at the transmitterwith a complete set of readings taken every half-hour, the chiefengineer was an important person.

Keep a current set of FCC rules on handat every station and familiarize yourself with any changes as they aremade.

The station engineer is often the person who prepares applicationsfor filing with the FCC, and who is responsible for the safe keepingand exhibition of licenses and associated FCC material. In smallstations the chief engineer should be consulted concerning thecompilation of the public information file (PIF) because of hisfamiliarity with the FCC. Responsibility for the compilation of the PIFshould not be dumped on the chief engineer alone. The station manager,or his responsible delegate, should work with the chief engineer. Onlythe station manager or his appointees will be familiar with the actionstaken to meet local listening area needs, or complaints concerningprogramming. Often signal interference letters are mailed to thestation but are lost on their way to the engineering department.

Many years ago the Commission's rules were divided into logicalgroups so that technical and administrative requirements were keptseparate. However, now that AM, FM and TV technical rules areinterspersed throughout Part 73, it becomes important to read everyrule.

When the FCC was formed in 1934, the existing rules inherited fromits predecessor, the Federal Radio Commission, were incorporated plusadditional rules necessitated by expanded broadcast activity. It seemsthat the number of rules peaked around the 1970-1980 period. Since thenthey have been decreasing in the old, original technical area, whileadding new technical rules as communications science advances in themore esoteric systems.

In the early days of radio broadcasting equipment tended to beunstable and its continuous performance capabilities were unknown. As aresult, it was necessary for the FCC to publish strict, and in manyways confining, rules to ensure efficient operation and preventinterference. Most of the old, restrictive rules have been eased,particularly in the area of AM directional antenna operation. It'sinteresting to note however, that the original AM frequency stabilityrule of plus or minus 20Hz has not changed.

The modern rulebook

There are a few former mandatory rules that still have big teeth inthem. Rules that once had such stern requirement for weekly or dailyinspection and verification, now say that these things should be doneas needed. Unfortunately (in the sense of being an essential action),the new rules nearly say “…must be made…” Isaid unfortunately because lacking a specific directive makes it iseasy to overlook such instructions. For example, consider rule73.1580.

Rule 73.1580 requires that regular inspections be made. No specifiedinterval is prescribed, nor is any method of record keeping indicated.Nevertheless, FCC inspection records will be required. Apart from thelegality of making periodic inspections, good engineering practicerequires that equipment be inspected and its condition noted. Not onlyis it a requirement, it becomes a useful piece of information whensomething breaks down.

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

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

E-mail Battison at batcom@bright.net.

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