I recently purchased an RV for two purposes. A great deal of my Public File work gives me reason to travel around the country, so the RV serves as our recreational vehicle and mobile office, which make my onsite work manageable while allowing me the space I need to work without intruding on the staff of the radio station.

So, last month we went on a long trip.

Now begins my essay on what I did during my summer vacation!

I secured a Public File consulting job with a radio station in Florida, so I packed up the family (yes, my daughter and several grandchildren) and set out on a 6,000 mile trip across the country!

After the project was completed, we did some typical tourist activities at Walt Disney World and the Kennedy Space Center. Those 6,000 miles covered 10 states. We listened to a lot of radio along the way. We also took many back roads and highways during the trip and noticed many communications and radio station tower lights out. Some stations did not seem to have any fencing around their tower, and many stations seem to be using satellite services for their source of programming.

As always, my time spent consulting radio stations on FCC Compliance brings up a lot of legitimate questions and concerns. Some of those comments I get are:

"Why doesn’t the FCC have a list of what is required to be in the Public File?"

" Why don’t they have a book on what they want us to keep?"

"I thought everything was de-regulated and we don’t have to do anything for our city of license any more".

There is a great deal of valuable information and material from FCC law firms. You can also search the Internet under FCC.gov and find the FCC Enforcement Bureau site as I mentioned in previous articles.

However, I understand that surfing the net and reading manuals on the subject of FCC Compliance is difficult when your payroll is coming due, your jocks don’t show up to work and the sales staff isn’t meeting its budget. I know that the Public File will come last on your list of priorities. You are not alone.

I have received numerous emails and telephone inquiries from broadcasters that ask me to travel to their station. This RV makes it more convenient (and enjoyable) to pay stations a visit, to help them bring their station or group in to full FCC Compliance. I quite enjoy it!

I understand when many do not have the money to fix the files or anything else. Some stations tell me they just pray that they don’t get inspected, because if they did, they wouldn’t have the funds to pay for the FCC fine.

When I returned from my trip across the country, I wanted to get answers for some of the questions I am asked. I called one of the FCC inspectors at the Washington D.C. FCC office, which handles the documentation and listings of the sales of radio properties. He wished to remain anonymous but explained that when a station sells, the FCC in Washington will contact the local Enforcement Bureau Director in that particular state, to notify them whether or not that station has been inspected recently.

I also questioned about the protocol if the station has moved their studio and office and did not notify Washington FCC about the move. My source told me that the FCC has a database where they keep that information accurate. They will call the station anonymously and ask for their current address.

Now, if the facts don’t match the FCC’s database and there was a mistake and the station did notify the Washington FCC office about the new location, they’ll investigate. All the more reason to be sure that the station should have a copy of that notice of location change in their Public File.

Additional questions I have come across are, if the station was using a STL to get their audio from this new location to the FM transmitter on top of a hill, then that application to change the STL location to show the new address should also be in their Public File.

Now, if that Public File was all in order and up to date, organized and in full FCC Compliance, the local manager would have the confidence to show the FCC inspector the Public File.

Now that’s talk briefly about the person that comes in just to look at the file. He could be anybody. It could be a competitor’s employee, a disgruntled former employee of the station, a political candidate, or even a local community advocate. They could just be there to make trouble for the station. Don’t snicker, its been known to happen.

He now could write the FCC a letter with just one small complaint about anything missing in the Public File and the FCC inspection flag goes up.

Now lets continue this in another manner. Suppose a year ago you had your state broadcasting association is visit your station to perform one of those state inspections. You paid the fee and the association notified the FCC. Now, according to agreement, your station will not be inspected for another guaranteed two to three years.

However, now you have moved your studio and office. If you did not notify the FCC, do you think that your "Get out of Jail Card" will help you on this one?

After I got back from my trip, I was really behind in my work. I had numerous emails to answer. I always enjoy reading from my readers of this column. Additionally, I have more work ahead for the fall.

If I made a commission on the fines I have been able to save for my clients, I could retire! I do however; enjoy my visits to your stations.

I can tell you it is better to be prepared and be in compliance in all respects than to open up a "Pandora’s Box". Emails are free, (at least for now) and if I can help please don’t hesitate to call or drop me a note. I got behind in my mail because of what I did this summer, but we really did enjoy our trip.

Sometimes I describe my FCC Compliance services as that of a gardener. Yes, as a homeowner, you are surely capable of taking care of your own lawn. When your grass needs fertilizer, you can study which product would make it greener. You can read books and ask questions on how to kill the dandelions and crabgrass, and you can plant and replant the flowers. When you need a sprinkler changed, you are certainly able to do that. Some homeowners enjoy it. But there are others who are too busy maintaining their household, going to work, and enjoying their off time to want to constantly worry about the yard, so they hire a gardener.

That’s me. I’m your FCC Compliance Gardner. I’ll take care of your stations compliance, so you can get on to the other important tasks that you must do!

Thanks for the comments about the San Francisco story that I wrote last month. If you missed it, go find your old issue and have a few laughs.

I plan to attend the NAB Convention in San Francisco later this month and join in on the few sessions regarding what the Enforcement Bureau looks for, and EEO Compliance issues. These are not usually the most popular sessions, but I’ll be one of the attendees, furthering my education that I can pass along to my clients.

I’ll let you know the latest in my next column.

Ken