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What to Do When the Inspector Knocks

Jim Dalke helps radio stations figure out whether they’re ready

From the beginnings of AM spectrum management to the complex and legalistic FCC rules of today, Jim Dalke takes engineers through the history of broadcast regulation and how they can navigate the complex system so that their facilities are compliant should an inspector come knocking.

Jim Dalke Dalke, CPBE, AMD, 8-VSB, is a contract engineer with Dalke Broadcast Services and editor of Waveguide, a publication of SBE Seattle Chapter 16. He will present “When the Inspector Comes Knocking” at the NAB Show on Wednesday, April 13.

“I want to go back and talk a bit about the history as it developed from the ’20s through the beginning of the inspection process, how that began with the Communications Act of 1934, and bring as much organization to it as is possible.”

He has seen firsthand the difficulties and errors that many stations face in complying with FCC regulations, through his work as both a contract engineer and an inspector for the Alternative Broadcast Inspection Program of the Washington State Association of Broadcasters.

Simply stated, compliance “takes a lot of discipline.”

Early concern

In his research Dalke came across an interesting comment about broadcast regulations.

“One of the people to popularize the term ‘radio’ was Lee de Forest when he incorporated the De Forest Radio Telephone Company,” Dalke said. In a letter in the June 22, 1907, issue of Electrical World magazine, de Forest warned that radio chaos would result unless stringent government oversight regulation was enforced.

“It kind of surprised me that the concern about it (regulations) went back that far. The point was that this led to the eventual establishment of the FCC in 1934. When they established that and gave the FCC the license process, they also gave the FCC some very extensive inspection capabilities to make sure that everybody that was licensed — AM radio, primarily, and eventually FM and TV — was carefully regulated. And with the regulation came their authority to perform these inspections.”

The Federal Communications Commission, an agency of the United States government, is charged with regulating non-federal government use of the radio spectrum, including TV, as well as other interstate telecommunications. The FCC has broad authority to inspect stations; it can go to any licensee 24 hours a day and inspect any part of a broadcast facility.

“When I’ve gone in to do my inspections, it occurred to me that people just don’t fully comprehend the inspection process itself,” Dalke says. The single biggest issue in compliance involves the public file.

“Many stations are putting copies of their public files online; there are pros and cons to this. There is a lot of stuff in the public file that the FCC says the public has the right to know, but on the other hand the stations may choose not to make it too available.”

The Enforcement Bureau of the FCC publishes a checklist to help licensees comply with broadcast regulations. Most on-scene inspections are conducted without prior notification to the licensee. Though proposals to require stations to post public files online have been debated, this remains a station decision at present; many choose not to do so for a number of reasons. Some stations furnish an electronic copy only on their intranet, with a simple computer terminal at the studio for public access, or choose to release only parts of the complete file on the public Internet.

Dalke tells clients problems also can arise when a station puts too much information into the public file. Broadcasters should supply nothing more than required while definitely providing nothing less.

These are the types of compliance areas where stations may need more guidance. Failure to follow the rules correctly can cost a station thousands of dollars in fines.

In the loop

“The public file is interesting in that technically engineers are not responsible for it, yet many engineers end up in this inspection loop,” Dalke said. However, it is the chief operator’s job to make sure the file is complete; and since many engineers also serve as chief operator, they should educate themselves on the process of maintaining the public file correctly.

Alternatively, Dalke says, they should enlist a certified inspector to ease the learning curve. Further, if a station has used an inspector from the Alternative Broadcast Inspection Program to complete the FCC’s Broadcast Station Checklist, the commission is less likely to make unannounced visits, he said.

At NAB he’ll also discuss the next generation of the Emergency Alert System and the Common Alerting Protocol. CAP is an open, interoperable, data interchange format for collecting and distributing emergency warnings. “The CAP systems add a whole other layer of responsibility for the station,” Dalke notes.

The ECIG Implementation Guide from the EAS-CAP Industry Group is one of the tools available to guide stations in this area. The guide is intended to facilitate the effective use and translation of CAP for broadcast EAS. The FCC is responsible for ensuring that communications providers have the capability to transmit and receive emergency alerts. As Radio World readers are aware, many broadcasters may need to replace EAS encoders/decoders or upgrade to meet the FCC mandate.