Lets begin with Station Logs:

The rule for station logs is found in Sec. 73.1800. The rule states:

(a) The licensee of each station must maintain a station log as required by Sec 73.1820. This log shall be kept by station employees competent to do so, having actual knowledge of the facts required. Any employee making a log entry shall sign the log, thereby attesting to the fact that the entry or any correction or addition made thereto, is an accurate representation of what transpired.

(b) The logs shall be kept in an orderly and legible manner.

You can go to the FCC Web site and look all the rules regarding station logs. What concerns us is that a station manager will have his secretary appointed as chief operator. We’ve given you the actual language so that readers would see that it really wants somebody competent to do so, having knowledge of the facts required.

Lets assume that your transmitter (AM or FM) is not in the same building where your studio and office is located. If you’re an AM station you are to enter the results of reading your monitor points once every three months. What? Also you must place into your station log that the measurements of your NRSC were done. Again; What?

Lets say that hypothetically, a meter has died, or a piece of equipment is found out of calibration, or something has been damaged or changed. Did you enter it into the station log? Huh?

A recent article from an FCC inspector suggested that the station manager should review the station’s log occasionally to see if they can reconstruct what the problem was and what was done to correct it. If the manager cannot read the station log or understand what problem occurred; then an FCC Inspector will not either.

We have not found a station manager in any market that even looks at the station log. Yet this simple piece of paper is to be kept for two years and could bring a large fine if not done correctly as specified by the rules of the FCC.

It seems as though many station managers are abdicating the responsibility of FCC compliance to those who don’t know what to do. And of course, the station manager is very good at maintaining the stations budget, so the first line of defense is to say "no" to the engineer in buying and updating EAS or test equipment.

Currently Orchard Media Services is performing many Volunteer Inspections of stations in and around California. What we have found is many are not able to pass and have to take many corrective measures before their station would be in full FCC compliance. We just completed a seven-station cluster and all seven stations failed for one reason or another. Some of the reasons for failure fall into these three categories:

not reducing its power to the license value at nighttime. During the inspection this problem was confirmed and this station was given a steep fine. As required, the station had to answer the FCC and stated in their response the personnel did not know how to operate the remote control for the station’s transmitter power level.

You are a new owner you have several months or years to fix items, think again. As soon as you take over the station and your deal has closed the responsibility for FCC compliance falls unto the new owner. That’s you.

Assistant Chief Lisa Fowlkes says the agency is strengthening its field operations and has allocated more funds for field inspections, and she notes that licensees with patterns of repeated violations are a top priority at the bureau. This NAB session also added that employees should cooperate and show the inspector what they want. At top of the list of problems at stations was again the dreaded Public File.

Compliance. The answer is a resolute, yes. It requires a special type of manager to understand the FCC rules and have an engineering background (or at least a knowledge of) as well as sales and programming. If you’re a new owner and are looking to hire a new station manager just make sure this new manager that you are interviewing at least knows what FCC means. Otherwise, it could mean a fine after the FCC visits.