The purpose of the article is to make you aware
that state environmental regulations may limit use of your station’s generator
in certain circumstances, and how that issue is playing out in one particular
Keep this bad boy tuned up …
and check your state regulations to make sure you don’t encounter unexpected
limitations in running it.
credit: WPWX(FM), courtesy Crawford Broadcasting
broadcasters are familiar with FCC Rules and Regulations. The FAA maintains jurisdiction
over tower construction. These two agencies are familiar to broadcast
engineers. Other government agencies regulate disposal of PCB-laden components
and hazardous materials. Facilities must adhere to Americans With Disabilities
(ADA) regulations, building, fire and electrical codes.
used during commercial power outages must be wired in accordance with the
National Electrical Code (NEC) by a licensed electrician and installed in
compliance with local regulations. The fuel supply must adhere to state and
local codes. The generator must be located a certain distance from an occupied
structure and protected from accidental vehicular contact. The same considerations
apply to propane or above-ground fuel storage tanks.
employed by broadcasters can vary widely in generating capacity. A studio site
generator may only power sufficient equipment to remain on the air or it can
power the entire facility, inclusive of heat and air conditioning. Facilities
with multiple stations can further increase the need for a larger generator. A
transmitter site generator may be sized to accommodate one or more
transmitters, environmental machinery, tower lights, etc. Sites with more than
one station may share a generator or there may be individual generators for
each broadcaster. Different fuel types may also be used. Some generators also
exercise at half-speed on no load.
must be at the ready to supply power when the commercial power fails. One
common method to ensure proper operation is to exercise the generator on a
regular basis. This may or may not involve placing a load on the generator. At
unattended transmitter sites this process is usually automated by a timer in
the transfer switch. The generator is programmed to start and run for a period
of time. Typical periods are weekly for 30 to 60 minutes. The generator’s
voltage and frequency can be locally or remotely monitored.
July 2012, Michael C. Rice, president of the Connecticut Broadcasters Association,
received an inquiry from the chief engineer of a station.
engineer related how he had been in the process of starting up the transmitter
site emergency generator, in anticipation of power outages likely to be caused
by severe thunderstorms heading into the area, when he received a visit from a
Connecticut Department of Energy and Environmental Protection field inspector.
DEEP inspector informed the engineer that on days for which the DEEP forecasts
“ozone air quality index levels classified as unhealthy for sensitive groups
(USG, or worse) anywhere in Connecticut,” an emergency generator can only be
operated — whether in anticipation of outages or for routine testing — when
there is an emergency, e.g., when there is in fact a power loss. The inspector
also informed him the station should be keeping logs on its generator
confirmed the field inspector’s assertions to be generally correct, though
generators with less than 3 million BTU hours’ output are exempt from record-keeping
and compliance plan requirements. (Much of the information here is from minutes
of the CBA board meetings.)
October, a public hearing was held to consider amendments to Section 22A-174-22
of the regulations of Connecticut State Agencies.
proposed amendments would permit nuclear and healthcare facilities (and
construction sites when construction interrupts power supply to the site) to
operate their generators on days with unhealthy air quality index levels in
order to maintain proper power levels. However, the proposed amendments do not
include testing and maintenance of broadcasters’ generators.
R. Hugabonne, an SBE member and chief engineer for a major radio station in
Connecticut, testified at the hearing on behalf of the CBA. Hugabonne pointed
out that all broadcasters are required to install and keep operational
Emergency Alert System equipment and use it to participate in EAS national
alerts. Additionally, virtually all stations participate in alerts activated by
state officials and the National Weather Service through the Connecticut State
further noted that the combined emergency generator emissions ofallbroadcast stations statewide is significantly less than those of
individual industrial buildings, power plants and institutional facilities.
Thus, he concluded, broadcasters too should be exempt from the restriction on
gen use during bad air days.
light of these facts the CBA proposed the following amendment:
Add to Section 2 as Section 22a-174-22(c)(2)(D)
(D)To test and anticipatorily start up emergency
power for production operations and transmission of Federal Communications
Commission-licensedradio and televisionoperators (whether broadcast, cable or satellite) so as to assure such operators suffer no interruption in production
or transmission if a power outage occurs.
to Elizabeth McAuliffe of the Connecticut DEEP, “At this point the proposal is
still just that, unless and until it is approved by the Legislative Regulation
Review Committee and the Secretary of State’s Office.”
would be wise for Radio World readers to investigate their state regulations to
see if similar restrictions are in place. If so, consider seeking relief
through state broadcasters association.
rely on the media to advise the public of hazardous materials incidents, road
closures, weather hazards and other safety issues as well as Amber and Silver
alerts. Broadcasters must have power to be able to broadcast under all
conditions. Exercising power generators is an essential ingredient to ensuring
this equipment is up to the task.
Tom Osenkowsky is a radio engineering consultant in
Brookfield, Conn., and a longtime RW contributor.