In these same cases, the FCC also found a number of technical violations at the tower sites, including:

• failure to have a locked fence around an AM station's tower,

• failure of stations to be operating at the power for which they were authorized, and

• failure to have a station's Studio Transmitter Link operating on its licensed frequency.

 

In one case, an AM station simply seemed not to be switching to its nighttime power.

 

In other words, at sunset, it was not reducing power from the power authorized for its daytime operations.

 

The second case was one where another AM station was not switching to its nighttime antenna pattern after dark.

 

In that case, there were apparently issues with the nighttime antenna.

 

Rather than request special temporary authority from the FCC to operate with reduced power until the problem was fixed, the FCC notes that the station apparently just kept operating with its daytime power.

 

An STA is not difficult to obtain when there is a technical issue (the FCC does not want stations going dark if it can be avoided), and some effort is made to specify a power that avoids interference to other stations.

 

So, if faced with technical problems, stations should request authority for operations that are different from those authorized by the station's license until those problems can be fixed, or risk a fine from the commission.

 

One of these cases also imposed a fine on a station for the failure of its STL to be operating on its assigned frequency.

 

The licensee admitted having had the STL transmitter modified to operate on the new frequency, but apparently the licensee had not asked the FCC for permission to operate on that new frequency in the six months since the rebuild.

 

Like so many other things, a station must follow the rules and file the correct papers to have the FCC approve the channel change (or a site change, as Davis Wright Tremaine has written about before) for a broadcast auxiliary license.

 

There are other issues like this that stations need to make sure are accurate (like registering a tower, updating the tower registration, observing tower lights, remembering to renew earth station licenses, and similar issues).

 

Fail to observe them, and a fine could be coming your way.

 

Finally, another recurring issue discovered in one of these cases was the failure to have an enclosed and locked tower site.

 

Davis Wright Tremaine has written many times about cases where the FCC has fined stations with unlocked fences, fences that are partially knocked down, or ones with holes that could allow access under the fence.

 

Here, the station had fenced all of the towers in its multi-tower AM array, but did not have a lock on the fence surrounding one of the towers.

 

The FCC is alert for violations and particularly alert to problems at transmitter sites that affect a station's radiation pattern or present safety issues.

 

So, check your operations.

 

Make sure that your bases are covered to avoid a nasty financial surprise should the FCC inspector come knockingTAB reminds stations that an easy way to ensure compliance with the FCC’s rules is to sign up for the Alternative Broadcast Inspection Program.

 

TAB's inspectors review stations for compliance with FCC regulations using the FCC's self-inspection checklists as a guide.

 

Compliant stations receive a three year waiver from FCC routine, drop-in inspections.