UPDATED MARCH 2000

Effective December 1, 1995, the FCC adopted new Rules to allow for unattended operation of broadcast transmitters. There have been numerous questions, and a great deal of confusion, regarding the exact interpretation and implementation of the Rules, especially when the station is operating with remote control and uses a dial-up telephone system. This memo is intended to clarify the new Rules with respect to what is commonly referred to as "walkaway station operation." This revision of the Rules is fully described in a Report and Order in MM Docket No. 94-130, released October 23, 1995.

When formulating the new remote control Rules, the Commission recognized that transmitters, as well as remote control systems themselves, have become considerably more reliable, thanks to advances in technology. Therefore, a logical offshoot of these advancements would be to lessen the burden of monitoring the equipment on station licensees. However, the Commission’s elimination of the requirement that an operator be on duty has no effect on the minimum staffing and main studio location rules. Also, statutory requirements continue to state that a person must be immediately available and responsible for broadcast equipment during all periods of operation and that EAS requirements are complied with regardless of the manner in which the station is monitored or controlled.

UNATTENDED OPERATION

In order to aid in a greater understanding of the new FCC requirements with respect to remote control operation, a summary of the Commission’s new Rules follows below.

• Although specific parameter logging or monitoring requirements do not apply to remote control system operation, (due to the varying nature of the facilities employing these systems), the licensee must insure that the station’s authorization (license) is adhered to at all times. (Recommendation: Even though logging of operating parameters is not required, stations are still required to operate within proper tolerances. Stations should continue to log parameters to show a history of compliance during an FCC inspection.)

• Authorized personnel may adjust the transmission system by phone from any location. A dedicated, dial up phone line must be installed for transmitter control purposes.

• For unattended operation, a designated duty operator is not required. However, the licensee must be in control of the transmitter at all times. The new Rules require that a station be able to turn the transmitter off within 3 minutes if interference occurs. Examples of interference include an AM array operating out of tolerance or mode and contact by the FCC. (Recommendation: Stations should employ a dial up remote control system with limits programmed into the unit so that the chief operator, and additional personnel as necessary, can be notified in case of an out of tolerance condition. When unattended, stations should provide a means for ready telephone contact from the FCC and the public.) Out of tolerance conditions, such as excessive modulation or transmitter power, must be corrected within three hours or the station must shut down. (Recommendation: See above.)

• Automatic alarms must be directed to a person, or persons, selected by the licensee. If a corrective response is not received by the remote control master equipment within three hours, the remote control should shut the transmitter off automatically. All stations must have the capability of shutting down within three minutes of receiving an FCC request due to interference.

• If remote monitoring fails, and is not restored within three hours, the station must place an operator at the transmitter site or the station must shut down. Any out of tolerance situation with interference potential, which cannot be resolved manually, requires the station to shut down immediately. Tower lights must be monitored on a daily basis. In the event that the entire tower lighting system fails, or any portion thereof, the FAA must be notified within 30 minutes of the failure. (Recommendation: Stations should monitor tower lights with the remote control and set up a call out alarm for a malfunction condition.)

Stations which choose to continue using operators no longer need to utilize licensed operators (typically holding a restricted permit). The Chief Operator requirements remain, in that each station must designate a Chief Operator, as well as an alternate, to be available when the Chief Operator is not available.

Once a station has EAS installed, the new Rules allow for a great deal of latitude in transmitter operation. Although the installation of automatic equipment to guarantee in-tolerance operation is not required, in-tolerance operation itself is required. This being the case, it would be wise for stations to continue to do periodic parameter logging to ensure compliance. A good log will demonstrate that the station has a history of compliance with the technical requirements of the station, and the FCC’s Rules.

Implementing unattended operations is clearly in the best financial interest of a station if it can be done without incurring liability. Another way to assure ongoing legal operation is to contract with a monitoring service. There are companies which offer limited daily meter readings, EAS monitoring, tower light monitoring, transmitter call out alarm response, and silent sense response for a minimal cost per month.

EMERGENCY ALERT SYSTEM ("EAS")

As of July 1, 1995, all existing Emergency Broadcast System (EBS) decoders were required to be replaced or modified to the specifications of the new Emergency Alert System (EAS) requirements. Existing EBS decoders can be modified by a qualified contract engineer which can eliminate the need to purchase new equipment at the outset, particularly if the present equipment is relatively new.

There are several worthy improvements to be gained at an approximate overall new system cost of $2,500.00. (Specifics related to cost of the systems vary by manufacturer, so it is best to obtain the most current pricing by contacting the manufacturer or local distributor directly.) Among these are the option to operate the equipment by remote control, the ability to target specific emergency information to an "at risk" geographic area (regarding emergencies such as tornadoes or nuclear accidents) and not alarm unaffected areas, and the reduction of confusion or failure due to human error. The multiple input system is a significant improvement as participating stations will no longer have to rely on just one station to receive an alert. Additionally, the ability of non-operating devices (such as televisions, car radios, stereo receivers, etc.) to receive a warning, even when the device is not on, is a significant obvious improvement over the previous technology.

The only stations exempt from the requirement to utilize any EAS equipment are LPTV stations used as a broadcast translator or booster, or an FM station used as a translator or booster dedicated entirely to the rebroadcast of programming of another broadcast station. Class D FM and low power TV stations are not required to have EAS encoders. All stations, except those totally exempt stations as noted above, must have EAS decoders.