CIB18 - FM

This is a copy of the On-Line version of the FM Broadcast Station Self-Inspection Checklist. It has been modified to serve as a documentation of our compliance with the items on the list. I hope to be able to demonstrate 100 percent compliance before y2k!

It is my hope to complete this project, then enroll in the TAB Alternative Broadcast Inspection Program.

Check the "Y" box if the station is in compliance with the item. Check the "P" box if the station is NOT in compliance with the item. Corrective action is pending. Notes concerning the action(s) taken to correct the area which is not in compliance. Check the "NA" box if the item does not apply to this station.

WHERE TO GET ASSISTANCE, FORMS and OTHER INFORMATION

On June 3, 1996, the FCC established a national call center in Gettysburg, Pennsylvania. This call center is operated by the FCC Compliance and Information Bureau (CIB). This facility is capable of providing services for the hearing impaired and the center is staffed full-time with bi-lingual (English and Spanish) Specialists. The toll free telephone number for this call center is 1-888-CALLFCC (1-888-225-5322).

Requests for Emergency Alert System (EAS) related documents should be directed to the Commission's EAS Office at (202) 418-1220.

Requests for any FCC form or bulletin should be directed to the Commission's forms distribution contractor at 1-800-418-FORM (1-800-418-3676). This is a voice mail answering system. You should have the number of the form available when you call.

The FCC, Mass Media Bureau, Audio Services Division maintains a web page at "http://www.fcc.gov/mmb/asd." This page provides information relating to radio broadcast, including a list of current telephone numbers available for inquiries. Current rules pertaining to AM and FM stations are maintained at "http://www.fcc.gov/mmb/asd/bickel/amfmrule.html."

SECTION I: ADMINISTRATIVE AND NON-TECHNICAL

A. AUTHORIZATIONS: The station license, construction permit, renewal certificate, auxiliary transmitter authorization, special temporary authorization (STA), and/or any other instrument of authorization shall be readily available and easily accessible at the station's principal control point. Renewal certificates should be associated with the corresponding station authorization. [See 73.1230(a), 73.1635, 73.1670, 73.3533, 73.3536, 73.3537 and 73.3539]

1. AUTHORIZATIONS: Are current station authorizations posted or readily available at the principal control point for the station?

Yes. The station authorizations are a red binder that is kept in the studio and in the Public Inspection file. The PI file is maintained in the office. The studio is the principal control point.

B. STATION LOGS/RECORDS:

STATION LOGS include entries pertaining to equipment status, equipment calibration, the Emergency Alert System (EAS) and the recording of tower light outages. STATION RECORDS include, but are not limited to chief operator designations and equipment performance measurements.

The station logs and records are to be kept in an orderly and legible manner, in suitable form and with sufficient detail. Station logs and records are to be retained for a period of two years, unless specified otherwise, and they shall be made available for inspection or duplication at the request of the FCC or its representatives. Required logs and records are to be readily available for inspection. [See 73.1225, 73.1226, 73.1590, 73.1800, 73.1820 and 73.1840]

2.LOGS/RECORDS: Are required station logs retained for a period of 2 years? [See 73.1840(a)]
The station log is maintained at the transmitter site, with the exception of the EAS portion of the log. The EAS portion of the log is maintained at the General Managers office. The records are retained for the required time.

3. AVAILABILITY: Are station logs/records readily available for inspection and/or duplication at the request of the FCC or its representatives? [See 73.1225 and 73.1226]The logs are readily available at each location. Since the transmitter is in a remote location, the logs would need to be removed and copied, then returned.

4. EQUIPMENT PERFORMANCE MEASUREMENTS: Are the latest Equipment Performance Measurements maintained and readily available? [See 73.1590(a)] Yes

5. CLARITY: Are the station logs legible and in such detail that they clearly document any problems that may have occurred at the station? [See 73.1800(b)] I will check them next time I am at the site. Perhaps a summary would be in order.

C. CHIEF OPERATORS: Each station must designate a chief operator. The designation is to be in writing with a copy posted with the station authorization. Agreement's with chief operators serving on a contract basis must be in writing with a copy kept in the station files. The chief operator is to review the station logs at least once each week to determine if required entries are being made correctly and to SIGN AND DATE the log upon completion of the review. The chief operator is also responsible for inspection and calibration of the transmission system, monitors, metering and control systems in addition to any equipment performance measurements or other tests as specified in the rules or terms of station authorization. [See 73.1870]

6. CHIEF OPERATOR DESIGNATION: Has the licensee designated a person to serve as the station chief operator? [See 73.1870(a & b)]Yes.

7. DESIGNATION POSTING: Is the designation in writing with a copy of the document posted or readily available? [See 73.1870(b)] YES

8. STATION LOG REVIEW: Does the station's chief operator review the station logs at least once each week to determine if required entries are being made? [See 73.1870(c)] Verify during next trip to site. Fred and I plan to meet after 4/15/99 to make an easy to enter/read log.

9. SIGNING STATION LOGS: Does the chief operator or a designee date and sign the logs upon completion of the weekly review of these documents? [See 73.1870(c)]
Verify during next trip to site.

D. STATION IDENTIFICATION: Station identification shall be made at the beginning and ending of each period of operation, and hourly, as close to the hour as feasible, at a natural break in program offerings. The identification shall consist of the station's call letters immediately followed by the community of license. Any reference to additional communities must be made after the community of license. The name of the licensee, or the station frequency, channel number, or both, may be inserted between the call letters and community of license. No other insertion is permissible. Simulcasted AM and FM stations may identify jointly if owned by the same licensee. [See 73.1201]

10. IDENTIFICATION: Is the station identification made in accordance with 73.1201? We will begin a systematic review of logs to insure ID's are being logged properly after meeting with New/Old PD's.

E. TELEPHONE ACCESS TO STATION: Each station must maintain a local or toll free telephone number within its community of license. Stations operating from studio locations outside of the community of license must make sure residents in the community have access to this number. [See 73.1125]

11. TELEPHONE ACCESS: Does the station maintain a local or toll-free telephone number in its community of license? [See 73.1125(d)] Yes.

F. PUBLIC INSPECTION FILE: All stations are to maintain a public inspection file at the main studio of the station. The file shall be available for public inspection at any time during regular business hours. Regular business hours are generally any eight hour period between the hours of 8 a.m. and 6 p.m. Monday through Friday.

All or part of the file 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 a station is concerned about documents being stolen or destroyed, then copies of required documents may be placed in the file in lieu of the originals.

The contents of the file are to be made available within a reasonable time for printing or machine reproduction upon request made in person, provided the requesting party pays the reasonable cost of reproduction. The licensee shall also mail photocopies of documents from the file upon request made in person, by telephone, by mail or e-mail, with all postage paid by the station. [See 73.3526 for commercial station public file rules and 73.3527 for non-commercial station public file rules]

12. FILE MAINTAINED: Does the station maintain a public inspection file in accordance with 73.3526(a)&(b) or 73.3527(a)&(b)? Yes

13. AVAILABILITY: Is the file available for public inspection at any time during regular business hours? [See 73.3526(c) or 73.3527(c)] Yes

14. REPRODUCTION: Can all of the materials contained in the public file be reproduced and provided upon request made either in person, by phone or by mail? [See 73.3526(c) or 73.3527(c)] Yes

15. AUTHORIZATION: Is a copy of the current FCC authorization to construct or operate the station being maintained in the file? [See 73.3526(e)(1) or 73.3527(e)(1)] Yes

16. APPLICATIONS: Does the public file contain copies of all applications, exhibits, letters, initial and final decisions in hearing cases, and other documents pertaining to the station which were filed with the Commission and which are open for public inspection at the FCC? This includes applications granted pursuant to a waiver. [See 73.3526(e)(2) or 73.3527(e)(2)] Yes

17. CITIZEN AGREEMENTS: For commercial stations, are copies of all citizen agreements maintained in the file for the term of the agreement? [See 73.3526(e)(3)] NA

18. CONTOUR MAPS: Is a copy of any service contour maps, submitted with any application tendered for filing with the FCC, together with any other information in the application showing service contours and/or main studio and transmitter location in the file? [See 73.3526(e)(4) or 73.3527(e)(3)] Yes

19. RETENTION OF CONTOUR MAPS: Are the station's contour maps retained for as long as they reflect current, accurate information regarding the station? [See 73.3526(e)(4) or 73.3527(e)(3)] Yes

20. OWNERSHIP REPORTS: For station licensees who are not sole proprietorships, does the public file contain copies of annual ownership reports and supplemental ownership reports filed with the Commission, including all exhibits, letters, and other documents associated with these filings? [See 73.3526(e)(5), 73.3527(e)(4) and 73.3615] Yes

21. OWNERSHIP INFORMATION: For non-commercial stations, does the ownership information on file with the Commission reflect the current ownership (board members, officers, etc.) of this station? [See 73.3527(e)(4) and 73.3615(d,e&f)] We are in the process of gathering the information.

22. CONTRACTS: For all stations, does the public file contain either a copy of the contracts listed in the latest ownership reports or an up to date list of such contracts for as long as they are in effect? [See 73.3526(e)(5), 73.3527(e)(4), 73.3615(a)(4)(i) and 73.3615(d)(3)] We are in the process of obtaining this information.

23. RETENTION OF OWNERSHIP REPORTS: Are ownership reports retained until a new, complete ownership report is filed with the FCC with a copy placed in the public inspection file? [See 73.3526(e)(5) or 73.3527(e)(4)] YES

24. POLITICAL: Does the licensee have a complete record of all requests for broadcast time made by or on behalf of candidates for public office, together with an appropriate notation showing the disposition made by the licensee of such requests, and the charges made, if any, if the request was granted? [See 73.1943 and either 73.3526(e)(6) or 73.3527(e)(5)]
YES

25. FREE POLITICAL TIME: If free time was provided for use by or on behalf of such candidates, has a record of the free time that was provided been placed into the file? [See 73.1943 and either 73.3526(e)(6) or 73.3527(e)(5)] NA

26. RETENTION OF POLITICAL RECORDS: Are these records retained for a period of two years? [See 73.3526(e)(6) or 73.3527(e)(5)] No political records exist to retain.

27. PUBLIC AND BROADCASTING: Does the station file have a copy of the most recent version of the manual entitled, "The Public and Broadcasting" available in the file at all times? [See 73.3526(e)(8) or 73.3527(e)(7)] YES

28. LETTERS FROM PUBLIC: For commercial stations, does the licensee retain all written comments and suggestions received from the public, including e-mail, regarding operation of their station unless the writer requested that the correspondence not be made public or the licensee felt that it must be excluded because of the nature of its content, such as a defamatory or obscene letter? E-mail copies may be kept either on the computer or on paper. [See 73.1202 and 73.3526(e)(9)] NA

29. RETENTION OF LETTERS: For commercial stations, are all letters retained for three years from the date received? [See 73.3526(e)(9)] NA

30. INVESTIGATIVE MATERIAL: Does the station have any material having a substantial bearing on a matter which is the subject of an FCC investigation or complaint to the FCC of which the licensee has been advised? [See 73.3526(e)(10) or 73.3527(11)] NA

31. RETENTION OF INVESTIGATIVE MATERIAL: Has this material been retained until the licensee is notified in writing that the material may be discarded? [See 73.3526(e)(10) or 73.3527(11)] NA

32. ISSUES-PROGRAM LISTS: Has the licensee maintained a list of programs that have provided the station's most significant treatment of community issues during the preceding calendar quarter? [See 73.3526(e)(12) or 73.3527(e)(8)] YES

33. FILED QUARTERLY: Was the issues-programs list filed by the tenth day of the succeeding calendar quarter (e.g. January 10, April 10, July 10, & October 10)? [See 73.3526(e)(12) or 73.3527(e)(8)] YES

34. NARRATIVES: Do the issues-programs lists include a brief narrative describing what issues were given significant treatment and the programming that provided this treatment? [See 73.3526(e)(12) or 73.3527(e)(8)] YES

35. DESCRIPTIONS: Does the description of the programs include at a minimum the time, date, duration and title of each program in which the issue was treated? [See 73.3526(e)(12) or 73.3527(e)(8)] YES

36. RETENTION OF ISSUES-PROGRAMS LISTS: Are the issues-programs lists retained for the term of the license? [See 73.3526(e)(12) or 73.3527(e)(8)] YES

37. DONOR LISTS: For non-commercial stations, does the licensee maintain a list of donors supporting specific programs? [See 73.3527(e)(9)] YES

38. RETENTION OF DONOR LISTS: For non-commercial stations, does the licensee retain such donor list(s) for a period of two years? [See 73.3527(e)(9)] YES

39. TIME BROKERAGE AGREEMENTS: For commercial stations, does the public file contain a copy of every agreement or contract involving time brokerage of the licensees station, or of another station by the licensee? Confidential or proprietary information may be removed. [See 73.3526(e)(14)] NA

40. RETENTION OF TIME BROKERAGE AGREEMENTS: Are these records maintained as long as the contract or agreement is in force? [See 73.3526(e)(14)] NA

***

41. LOCAL ANNOUNCEMENTS: Was a statement certifying compliance with the local public notice filing announcements placed into the file within 7 days of the last day of broadcast of such announcements? [See 73.3526(e)(13), 73.3527(e)(10) and 73.3580(h)] YES, but the station missedtwo of the required announcements. It seems that the station was unaware of the requirement and need to renew. It seems to have made a good faith effort to comply with the rules when it discovered their oversight.

42. RETENTION OF LOCAL ANNOUNCEMENTS: Was the statement certifying compliance with 73.3580(h) retained until final action is taken on the application to which it refers to? [See 73.3526(e)(13) or 73.3527(e)(10)] YES

G. MAIN STUDIO PRESENCE: Each station must maintain a presence at the main studio during normal business hours so members of the public can reach responsible station personnel and receive access to the public inspection file. In addition, a main studio presence allows the licensee to make the station available at any time during normal business hours. Normal hours are typically an 8 hour period between 8:00 a.m. and 6:00 p.m. local time Monday through Friday. This requirement is separate from the unattended transmitter operation rules. [See 73.1125 and 73.1225(a)]

43. MAIN STUDIO PRESENCE: Does the licensee maintain a human presence of at least 8 hours per week day at the station's main studio? [See 73.1125 and 73.1225(a)] YES

H. MAIN STUDIO LOCATION: The main studio for each station shall be located within the principal community signal strength contour of any broadcast station licensed to that same community or 25 miles from the reference coordinates of the center of its community of license, whichever the licensee chooses. [See 73.1125]

44. MAIN STUDIO LOCATION: Is the main studio for this station located within the principal community contour of any station or within 25 miles of the reference center? [See 73.1125] YES

H. SUBCHANNEL LEASING AGREEMENTS: FM subchannel leasing agreements for subsidiary communications are to be kept at the station and made available for inspection by any authorized representative of the FCC upon request. [See 73.1226(c) and 73.3613] NA

45. SCA AGREEMENTS: Are all subchannel leasing agreements maintained and available at the station? [See 73.1226(c)(2)] NA

SECTION II: ANTENNA STRUCTURES

A. ANTENNA REGISTRATION: Most antenna structures that are higher than 60.96 meters (200 feet) above ground level or that may interfere with the flight path of a nearby airport must be studied by the Federal Aviation Administration (FAA) and registered with the FCC. Owners are required to register their non-exempt tower structures with the FCC. All proposed and altered antenna structures must be registered prior to construction or alteration. For licensees this means that the tower must be registered before a new construction permit or license modification involving the tower or antenna is granted.

Licensees should be familiar with the painting and lighting specifications shown on their station authorization. In the event that the structure owner is unable to maintain the prescribed painting and lighting, e.g. in cases including but not limited to abandonment, negligence, or bankruptcy, the FCC would require that each tenant licensee on the structure undertake efforts to maintain painting and/or lighting. Additionally, if the licensee has reason to believe that the structure is not in compliance or that the owner is not carrying out its responsibility to maintain the structure, the licensee must immediately notify the owner, notify the site management company (if applicable), notify the FCC, and make a diligent effort to ensure that the antenna structure is brought into compliance.

Once a tower is registered, then the registration number(s) is to be displayed in a conspicuous place so that it is readily visible near the base of the antenna structure(s). When the tower is located where the number cannot be seen without access to the property on which it is located, then the number should also be placed on the gate or fence leading to the tower where an outside observer can see it. Materials used to display the registration number must be weather-resistant and of sufficient size to be easily seen.

An informational FACT SHEET, PR5000-15, "ANTENNA STRUCTURE REGISTRATION", and the Antenna Structure Registration Form (FCC Form 854), may be obtained by contacting the FCC's Forms Distribution Center at (800)418-3676. This document will provide information on how to register a tower. Users may also visit the FCC's Internet Homepage at "http://www.fcc.gov/wtb/antstruc.html" for up to date information on filing procedures, electronic filing and database access.

46. Registration: Has the owner of the tower on which the station antenna is mounted obtained registration for the structure? [See FACT SHEET - PR5000-15] YES

47. Posting of Number: Has the registration number been posted in an easily viewed location at the tower site? [See FACT SHEET - PR5000-15] YES

B. ANTENNA SPECIFICS: The construction permit, station license, or other instrument of authorization provides authority for the station to operate under a specific set of operating parameters. The licensee must thoroughly review the current station authorization, and where applicable the structure registration, to compare the listed specifications to the location, height, etc. that is actually used by this station. [See the Terms of the Station Authorization (TSA)]

48. OVERALL HEIGHT: Does the overall height of the structure match that specified in the station authorization and, where applicable, the structure registration? [See TSA] The bid specs show the tower to be 30 feet shorter than the FCC specs. I will try to verify next visit to the transmitter.

49. ANTENNA: Does the number and height of the antenna bays match that specified in the station authorization? [See TSA] I will verify the next trip to the transmitter.

50. LOCATION: Does the street address and geographical coordinates of the station transmitter/tower location match exactly with the information shown on the station authorization and, where applicable, the structure registration? [See TSA] I will verify next visit to transmitter. I have asked Dr. Bill to loan his GPS.

C. TOWER LIGHT OBSERVATIONS: The lighting on tower structures is to be observed at least once every 24 hours either visually or by observing an automatic indicating device; or alternatively the licensee/tower owner may provide and maintain an automatic alarm system to constantly monitor the lighting on a structure. All automatic or mechanical control devices, indicators, and alarm systems are required to be inspected at intervals NOT TO EXCEED 3 months. [See 17.47]

51. OBSERVATIONS: Is the lighting on the tower(s) observed at least once every 24 hours either visually or by observing an automatic indicating device; or alternatively has the licensee/tower owner provided and maintained an automatic alarm system? [See 17.47] In the process setting up an automatic alarm system.

52. ALARM MAINTENANCE CHECKS: Have all automatic or mechanical control devices, indicators, and alarm systems been inspected within the last 3 months? [See 17.47] I will ask fred and try to get online with the modem software. Also look at the station log.

D. PAINTING/LIGHTING: The station authorization and/or tower registration specifies the painting and lighting requirements for your operation. This is shown as a set of numbers or letters which correspond to paragraphs found on FCC Form 715 (Numbers - For towers with beacons and side lights) or 715A (Letters - For towers with strobed lighting), or the most current FAA Advisory Circular on Marking and Lighting. If no painting or lighting is required, then the authorization will specify "NONE" or "NONE REQUIRED". Tower registration is only necessary when painting and/or lighting is required.

The licensee must make certain that the number and placement of paint bands and lighting match exactly with that shown on the station authorization and/or tower registration. The licensee/tower owner should also be aware of the requirement to clean or repaint tower structures as often as necessary to maintain good visibility to aircraft. [See Part 17 and TSA]

NOTE: One of the most common problems associated with tower painting is the feedlines that are on the outside legs of a tower. In many cases, the tower is painted correctly, but the solid black colored feedlines defeat the purpose of the painting by covering up the outside legs of the tower. The licensee/tower owner should make certain that the feedlines are also painted in such instances. This does not apply in cases where the tower is authorized for strobe lighting.

53. PAINT SPECIFICATIONS: Does the painting on the tower structure(s) match the specifications in the station authorization? [See TSA] Alternating white and aviation orange. Top and bottom need to be orange. Should be ~ 7 bands... not more than 100 feet, not less than 1.5 feet. I will verify this next visit.

54. PAINT BANDS: Does the structure have the correct number of bands and are the top and bottom bands painted orange? [See Part 17] See above.

55. LIGHTING SPECIFICATIONS: Does the lighting on the tower structure match exactly with the specifications in the station authorization? [See TSA] Top and half way should be flashing beacons. 1/4 and 3/4 should be steady red globes. All should be red. Beacons should flash 12-40 times per minute.

E. FAA NOTIFICATIONS: The licensee is to notify the nearest Federal Aviation Administration (FAA) Flight Service Station 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 the structure. Such improper functioning beacons include non-lighted beacons as well as those that are lighted, but non-flashing. Notification is to also be made immediately to the FAA once the beacon or steady burning top light is returned to service. Notification is not required when side light outages are observed. Tower owners/licensees should insure that the telephone number to the nearest FAA Flight Service Center is readily available and known to all personnel who would be responsible for notifying the FAA of such outages. [See 17.48]

56. FAA NOTIFICATION: Are the tower owner/licensee and all station operators aware of the requirement to notify the nearest FAA Flight Service Station within 30 minutes of the observation of an outage AND to notify the FAA again once the outage is corrected? [See 17.48] YES? Inform GM. Have me and Fred paged.

F. STATION LOGS: For all stations operating from a tower owned by the licensee and which have authorizations that specify tower lighting, the licensee/tower owner is to make entries in the station log concerning ANY observed or otherwise known extinguishment or improper functioning of ANY tower light regardless of its position on the tower. [See 17.49, 73.1213 and 73.1820(a)(1)(i)] This log 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.
Date and time of FAA notification, required for outages of any flashing light.
The date, time and nature of adjustments, repairs or replacements made.

57. STATION LOGS: Does the licensee/tower owner maintain a station log containing entries concerning ANY observed or otherwise known extinguishment or improper functioning of ANY tower light? [See 17.49, 73.1213 and 73.1820(a)(1)(i)] Verify next trip to site.

SECTION III: EMERGENCY ALERT SYSTEM (EAS)

On December 9, 1994, the Commission released a report and order which relocated the Emergency Broadcast System (EBS) rules of Part 73 to the newly established Emergency Alert System (EAS) rules under Part 11. This new rule part reflects the expansion of EAS into other radio services, including cable, along with establishing the move from the analog technology used in EBS to the digital technology used with EAS.

All FM broadcast stations must have installed operational EAS equipment capable of sending and receiving the digital EAS protocol. If there are any questions pertaining to the new EAS rules then please contact the Commission's EAS office at (202) 418-1220.

A. PARTICIPATING vs. NON-PARTICIPATING: The difference between a "Participating" and a "Non-Participating" station occurs during national level Emergency Activation Notification (EAN) alerts. Upon receipt of an EAN the participating station will stay on the air providing necessary information while the non-participating station takes its carrier off the air. All stations are considered participating stations, unless they submit a written request to become a non-participating station, AND they receive a written authorization to that effect. Regardless of their participating or non-participating status, ALL stations are to install and maintain EAS equipment and participate in the weekly and monthly tests of the system. Additionally, all stations are required to monitor for state and local EAS activations. Once a state or local level activation has been received, the station management can then decide whether or not to participate further at that level. [See 11.19, 11.54, 11.55 and the EAS plan for your state]

58. PARTICIPATING: Does the management of this station know whether the station is a participating or non-participating EAS station? YES

B. HANDBOOK: All stations are to maintain an EAS Operating Handbook. The handbook is to be available at ALL EAS control points. Please contact the EAS office for copies of the handbook. [See 11.15]

59. HANDBOOK: Does the station have an EAS Operating Handbook available at EACH EAS control point utilized during any portion of the broadcast day? [See 11.15] YES

C. EAS DECODER/MONITOR: All FM stations must have equipment installed and capable of decoding, either manually or automatically, the digitally encoded EAS protocol while monitoring at least two assigned EAS stations. This equipment must be operational during all hours of broadcast operation. Manually operated equipment must be located so that operators, at their normal duty stations, can be alerted immediately when EAS messages are received. Only one EAS decoder is required for combined facilities operating from one common location, such as a co-owned and co-located AM and FM studio. All decoder devices are to be certified by the Commission in accordance with Part 2 Subpart J of the Commission's rules. [See 11.31, 11.33, 11.34, 11.35 and 11.52]

60. CERTIFIED EQUIPMENT: Does the station use only certified equipment at each location utilized for EAS monitoring? YES[See 11.34]

61. EQUIPMENT STATUS: Is the required EAS decoding/receiving equipment currently installed and in operational condition? [See 11.35] YES

62. INSTANTANEOUS ALERT RECEPTION: For manually operated EAS decoding equipment, is the decoder installed in a way that enables broadcast station staff to be alerted instantaneously upon receipt of an activation occurring during any portion of your broadcast operation? [See 11.52] YES

63. MONITORING ASSIGNED STATION: Is the EAS decoder/monitor tuned to receive EAS activations from the monitoring priorities named in the FCC-EAS Mapbook or State EAS plan? [See 11.52 and the FCC-EAS Mapbook]
No. Contact Frank Lucia to get written authorization of deviation. Verbal has been given.

D. EAS ENCODER/GENERATOR: All FM stations are to have installed and operational equipment capable of transmitting the digitally encoded EAS protocol. The equipment may be installed for either manual or automatic activation of the generator. If manual activations are used, the EAS encoder must be located so that station staff, at normal duty locations, can initiate the EAS code and Attention Signal transmission. Only one generator is required at combined studio facilities. Any encoder device used for generating the EAS Protocol and Attention Signal must be type accepted. [See 11.34, 11.35 and 11.51]

64. CERTIFIED EQUIPMENT: Does the station maintain certified equipment capable of generating the EAS protocol to modulate the transmitter so that the signal may be broadcast to other receiving stations? [See 11.34] YES

65. EQUIPMENT STATUS: Is the required EAS encoding/generating equipment currently installed and operational at this station? [See 11.35] YES

66. LOCATION: For manually operated equipment, is the equipment positioned where responsible broadcast staff can initiate an activation during any portion of the broadcast day? [See 11.51] YES

E. EAS TESTS: All FM stations are to conduct required weekly tests (RWT) of the EAS header and End of Message (EOM) codes a minimum of once a week at random days and times, which can include any time of the day or night. In addition, required monthly tests (RMT) are to be conducted once a month as coordinated by the Emergency Communications Committee for each state. The EAS weekly test is optional during the week that a monthly test is conducted. The monthly test conducted in odd numbered months shall occur between 8:30 a.m. local time and local sunset. The monthly test conducted in even numbered months shall occur between local sunset and 8:30 a.m. local time. [See 11.61]

Note1: Since stations are required to monitor two EAS sources, then each station should receive at least one RWT from each of the two sources. The RMT may result in only one test being received during that week.

Note2: If the station is not operating at the time an RMT is scheduled, then the licensee shall log that they were off the air and an RWT should be aired some time during the week after operation of the station resumes.

67. CONDUCT EAS TESTS: Does the station conduct RWT/RMT transmission tests of the EAS header and EOM codes a minimum of once a week at random days and times? [See 11.61(a)] YES

68. RECEIPT OF EAS TESTS: Did the station receive two EAS test activations during the last full calendar week from its two assigned EAS monitoring sources? [See 11.61(a)] YES

F. STATION LOGS: All stations are to maintain a station log containing entries pertaining to each test of the Emergency Alert System that is received or initiated by the station. EAS test entries must be made in the station log either manually by responsible broadcast station staff, or by an automatic device. Stations may keep EAS test data in a special EAS log which can be maintained at any convenient location; however, such log must be considered a part of the official station log. It is also to contain entries which adequately describe the reason why any test activation was not received and any corrective action taken. [See 11.35(a), 11.51(j), 11.52(e), 11.61(b) and 73.1820(a)(1)(iii)]

Whenever any EAS equipment becomes defective, the station may operate without the defective equipment, pending its repair or replacement, for a period not in excess of 60 days. The station must make appropriate entries into the station log showing the date and time the equipment was removed and restored to service. [See 11.35(b)]

If the station cannot restore service to the defective equipment within 60 days due to conditions beyond the control of the licensee, then the station must request an extension of this time from the FCC District Director of the area in which the station is located. Such request shall include the steps that were taken to repair or replace the defective equipment, the alternative procedures being used while the defective equipment is out of service and an estimation when the defective equipment will be repaired or replaced. [See 11.35(c)]

69. STATION LOGS MAINTAINED: Does the licensee maintain a station log containing an entry of each test (both sent and received) of the Emergency Alert System (EAS)? [See 11.51(j), 11.52(e), and 73.1820(a)(1)(iii)] YES

70. FAILURE TO RECEIVE EAS TEST: Does the station log contain appropriate entries indicating the reasons why required EAS Weekly/Monthly test transmissions were not received? If all tests have been received and logged during the last two year period, then the appropriate response is yes "Y". [See 11.35(a)] No, but this is being corrected. The logs are reviewed weekly. Will integrate RF reading log and EAS log into one log.

71. EQUIPMENT OUTAGE: Does the station log contain appropriate entries documenting the date and time any EAS equipment was removed and/or restored to service? If there have been no such outages in the last two years, then the appropriate response is yes "Y". [See 11.35(b)] YES

SECTION IV: TECHNICAL REQUIREMENTS

A. POWER: All FM stations operating with more than 10 watts are to maintain operating power between 90% and 105% of that authorized. The power is to be maintained as near as practicable to the station's authorized power. [See 73.1560 and TSA]

In the event that it becomes technically impossible to operate at authorized power, a station may operate at reduced power for a period of not more than 30 days without specific authority from the FCC. If operation at reduced power will exceed 10 consecutive days, a notification must be sent to the FCC-Mass Media Bureau no later than the 10th day. If normal power is restored prior to the expiration of the 30 day period, the licensee must notify the FCC upon restoration of normal operation.

72 OPERATING POWER: Is the station's operating power between 90% and 105% of that authorized? [See TSA and 73.1560] YES

B. DIRECT vs INDIRECT METHOD: The operating power of FM stations may be determined by either the direct or indirect method. The direct method of power determination for an FM station uses the indications of a calibrated transmission line meter located at the RF output terminals of the transmitter. This meter must be calibrated whenever there is any indication that the calibration is inaccurate or whenever any component of the metering circuit is repaired or replaced.

The indirect method is determined by applying the appropriate factor to the input power to the last radio-frequency power amplifier stage of the transmitter, using the following formula:

Transmitter output power = Ep x Ip x F

Where: Ep = DC input voltage of final radio stage.

Ip = Total DC input current of final radio stage.

F = Efficiency factor of the transmitter.

The value of the efficiency factor, F, is to be determined and a record of its value is to be maintained and available upon request. [See 73.267]

Licensees must make certain that all duty operators know which method of power determination is being used and how to calculate the output power based on that method.

73. EFFICIENCY FACTOR: Is the efficiency factor known for each transmitter used and a record kept as to its value, along with the source from which this value was determined? [See 73.267(c)] ?YES

C. FREQUENCY: The departure of the carrier or center frequency of an FM station with a licensed output power of more than 10 watts may not exceed 2000 Hz from that authorized. For stations operating with 10 watts or less the tolerance is 3000 Hz. [See 73.1545]

74. FREQUENCY: Is the station in compliance with the frequency tolerance specified in 73.1545? Need to determine how to make this measurement.

D. MODULATION: The total modulation may not exceed 100 percent on peaks of frequent reoccurrence with reference to 75 kHz deviation. However, stations using subsidiary communications, also known as subcarriers or SCA's, may increase the peak modulation .5 percent for each 1.0 percent subcarrier injection up to a total of 110 percent (82.5 kHz peak deviation). [See 73.1570]

75. MODULATION: Is the station in compliance with the modulation limits specified in 73.1570(b)? Look up section and verify QEI is set for 100% not 105, since the SCA is off the air. Also, bring but set to listen to SCA output from QEI.

E. TRANSMITTER METERING & CONTROL: All FM stations are to maintain sufficient metering to determine compliance with power and modulation. In addition, where applicable stations may need monitoring devices to determine compliance with antenna tower lighting. All stations must have personnel which maintain the ability to turn off the transmitter. [See 73.1350]

76. CONTROL: Does the equipment at this station allow transmitter control personnel the capability of turning off the transmitter at any time the station is in operation? [See 73.1350(b)(2)] YES

77. OPERATING PARAMETERS: Does the licensee maintain necessary metering to determine compliance with power and modulation? [See 73.1350(c)] YES

F. MONITORING PROCEDURES: The licensee must establish monitoring procedures and schedules for the station. Monitoring procedures and schedules must enable the licensee to determine compliance with operating power, modulation levels and where applicable with antenna tower lighting. Licensees should be able to provide upon request made by the FCC, the monitoring procedures and schedules they have established for each station.

In the event that an FM broadcast station is operating with excessive power, or with excessive modulation, then station operation is to be terminated within 3 hours, unless corrective action is taken prior to that time. [See 73.1350(d)]

78. SCHEDULES: Has the licensee established procedures and schedules for monitoring the power and modulation at this station? [See 73.1350(c)(1)] YES

G. CALIBRATION: The licensee must conduct periodic complete inspections of the transmitting system, all required monitors and automatic logging devices to ensure proper station operation. Monitors and automatic logging devices must be periodically calibrated so as to provide reliable indications of transmitter operating parameters with a known degree of accuracy. The determination as to how frequent the complete inspection and calibrations are to occur is up to the licensee. The licensee should make certain that the date of calibration of each device is entered in the station log along with any other resulting actions associated with the calibration, such as replacement of a meter or other device. The licensee may keep calibration data in a special calibration log, however, such log must be considered a part of the official station log and as such must be made available upon request. [See 73.1350(c), 73.1580 and 73.1820(a)(2)(iii)]

79. CALIBRATION: Has the licensee established procedures and schedules for conducting periodic inspection of the transmitting system and all monitors, and to periodically calibrate these devices? [See 73.1350(c) and 73.1580] Not formally, should be done in consultation with Fred.

80. LOGGING: Are the results of such calibration entered into the station log? [See 73.1820(a)(2)(iii)] Look at log and ask FRED.

SECTION V: ATTENDED VS UNATTENDED OPERATION

A. ATTENDED VS UNATTENDED: Broadcast stations may be operated as either attended or unattended facilities. No prior FCC approval is required to operate a station in the unattended mode. Regardless of which method of station operation is employed, licensees must employ procedures which will ensure compliance with the EAS rules. [See 73.1300]

ATTENDED OPERATION: Attended operation consists of ongoing supervision of the transmission facilities by a station employee or other person designated by the licensee either at the transmitter site, a remote control point, or an ATS control point. Such supervision may be by direct observation and control of the transmitting system by a live person at the transmitter site or remote control point, or such supervision can be by automated equipment that is configured to contact a person designated by the licensee. In either case a live person must be on duty at a FIXED location during all hours of broadcast operation where they can turn off the transmitter and where they can either monitor the station operating parameters themselves or be contacted by the automated equipment which is monitoring the equipment for them. During attended operation, it is expected that the transmitter will be turned off by station personnel within 3 hours of an overpower or overmodulation condition that can cause interference that cannot be corrected within that period of time. [See 73.1350 and 73.1400(a)]

UNATTENDED OPERATION: Unattended operation consists of using self-monitoring or automatic transmission system (ATS) monitoring equipment to control the transmission system, or alternatively, operation in the absence of constant human supervision with equipment that can operate for prolonged periods of time within assigned tolerances. In the former case, equipment must be configured to automatically take the station off the air within the required 3 hour or 3 minute time periods after an out-of-tolerance condition arises. In the latter case, the licensee is required to make certain that the station is monitored frequently enough to ensure that station operation is corrected or terminated within the designated 3 hour time limit, but constant human supervision is not required. [See 73.1350(c) and 73.1400(b)]

NOTE 1: The unattended transmitter operation rules are separate from the main studio presence requirements. Please do not confuse the two. Stations operating in an unattended transmitter monitoring mode are still required to maintain a human presence at the main studio during normal business hours.

NOTE 2: A Mass Media Bureau Fact Sheet on Unattended Operation may be found on the Internet at "http://www.fcc.gov/mmb/asd/bickel/noonehome.html".

81.UNATTENDED: Does the licensee maintain either automated equipment or periodic human monitoring that enables station operation to be corrected or terminated within 3 hours after an out-of-tolerance condition arises? [See 73.1350(c) and 73.1400(b)] NA

82.ATTENDED: Does the licensee maintain a person on duty at a fixed location during all periods that the station is on the air where they can either monitor and control the station themselves or be contacted by automatic transmitter monitoring equipment within 3 hours after an out-of-tolerance condition arises? [See 73.1350(c) and 73.1400(a)] I'm not sure if the system we have now meets this requirement. Look at the cited sections to determine compliance.

B. NOTIFICATION: Whenever a transmission system control point is established at a location other than at the main studio or transmitter, then notification of that location must be sent to the FCC, Mass Media Bureau , 1919 M. St., N.W., Washington, D.C. 20554, within 3 days of the initial use of that point. This notification is not required if responsible station personnel can be contacted at the transmitter or studio site during hours of operation. [See 73.1350]

NOTE: Notification of an alternate control point should be a separate notification and not a part of another action or notification you are sending to the Commission. An informal letter is sufficient notification. Please make certain that the letter includes the complete street address of the control point as well as a telephone number. The licensee should also include the hours that this point is normally being used as the control point.

83. NOTIFICATION: Has the licensee notified the Mass Media Bureau in writing of the location of all transmission system control points other than the main studio or transmitter location? [See 73.1350(g)] Again, look at section to determine what is really meant...

84. STATION RECORDS: Is a copy of this notification available in the station records? See above.

SECTION VI: LOCAL MARKETING AGREEMENT (LMA)

DEFINITION: "Time brokerage", also known as "Local Marketing Agreement" or "LMA", is the sale by a licensee of discrete blocks of time to a "broker" that supplies the programming and commercial spot announcements to fill that time.

A. LMA STATUS:

85. LMA STATUS: Has this station been engaged in a time brokerage agreement during any portion the current term of the station authorization? NO

NOTE: If this station has not been engaged in a time brokerage agreement during any part of the current term of the station license or other authorization, then you are not required to answer any further questions contained in this section (Section VI).

B. FILING OF CONTRACTS: All stations involved in an LMA must file a copy of the agreement in the stations public inspection file. In addition, the LMA agreement must be filed with the FCC, Mass Media Bureau , 1919 M. St., N.W., Washington, D.C. 20554, within 30 days of execution if a licensee in the same market is brokering the station and providing more that 15 percent of the time on the brokered station. Confidential or proprietary information may be marked out in the copies placed in the public inspection file and this same information may be marked out in the copies filed with the Commission, however, such information shall be made available for inspection upon request by the FCC. [See 73.3526(a)(12) and 73.3613(d)]

A list of all contracts still in effect, which are required to be filed with the FCC in accordance with 73.3613, are to be filed with the annual ownership report. This list shall include the date of execution and the expiration of each contract and the list shall document any interest which the licensee may have in any other broadcast station. [See 73.3615(a)(4)]

86. FILING: Has the licensee submitted a copy of the LMA to the FCC within 30 days of execution of the agreement? NA

87. LISTS: Has the licensee provided a list of all contracts in effect along with the annual ownership report? NA

C. CONTROL OF THE STATION: There is no exact formula by which control of a broadcast station can be determined. However, the FCC has traditionally held that the licensee has ultimate responsibility over essential station matters, such as personnel, programming and finances. Licensees are required to maintain control of their stations regardless of who is brokering the station. [See Title 47 United States Code Section 310(d) and 73.3540]

88. CONTROL: Has the licensee maintained control over this station? YES

D. MAIN STUDIO: Licensees are required to maintain a meaningful management and staff presence at stations, even when they are engaged in an LMA. The Commission has interpreted this to mean full-time managerial and full-time staff personnel are to be employed and present at the station during normal business hours. [See 73.1125]

89. PRESENCE: Does the licensee maintain full-time managerial and staff personnel at the station during normal business hours when the station is brokered? NA

Where:	Ep = DC input voltage of final radio stage.
	Ip = Total DC input current of final radio stage.
	F = Efficiency factor of the transmitter.

Table of Contents

INTRODUCTION