In addition to serving as a Media Information Bureau featured columnist, Ken Benner is an independent Alternative FCC Compliance Certification Inspector and a research analyst for the Coalition for Transparency, Clarification and Simplification of Regulations pertaining to American Broadcasting.
He has more than 55 years of experience providing service to the broadcast industry. Who will follow in this octogenarian’s footsteps? It could be you.
Here is his second installment in a series of columns written for individuals that have an interest in knowing what it takes to be an Alternative Broadcast Inspection Program (ABIP) expert.
How To Become A “Mock” (or Alternative) FCC Inspector
By Ken Benner, CBRE, NCE
I have long been a firm believer of the saying, “If it isn’t in black and white, it doesn’t exist.”
Using this mantra, from here on in my columns on this subject, we will concentrate our discussion on the documentation supporting any inspection compliance certificate any of us issue.
For these RBR+TVBR Media Information Bureau articles, be sure that what I share with you is only documentable information. I ordered a copy of the Code of Federal Regulations Title 47. Pt. 70-79. revised as of October 1, 2016.
There is an update of this, as of December 2017. It is currently available via the U.S. Government Publishing Office website.
I suggest you consider a similar purchase. The price post-paid is just $67.00, and I consider it to be a small price to pay when seeking to avoid nearly any possible alleged FCC violation. And, it doesn’t require a law degree to interpret anything in it.
To begin our first taask, please do the following:
Take seven 8-1/2 x 11 sheets and title one-side (Page 1) with each of these titles:
1) AM BROADCAST STATION CHECKLIST
2) FM BROADCAST STATION CHECKLIST
3) TV BROADCAST STATION CHECKLIST
4) CLASS A TV BROADCAST STATION CHECKLIST
5) FM TRANSLATOR CHECKLIST
6) LPFM CHECKLIST
7) LOW POWER TV, TV TRANSLATOR & TV BOOSTER CHECKLIST
That’s all for now. Just put one line at the top of each of those sheets.
We will cover what is added below those titles in our next column.
Today, we want to cover what appears on the reverse side of those sheets.
Why? While it is simple, it is very important in that it provides the inspector’s mandatory documentation for station compliance certification.
The next page is identical for each of the seven topics listed above:
Page 2 of 2
Broadcast Antenna Tower Survey (FCC File 1130-A as modified)
Use a separate line for each item related to appear like this:
_______Registration, Fact Sheet – PR-5000-15
_______Posting of Number, Fact Sheet – PR-5000-15
From your AM Check List pages 9-12 continue with each of the items from 49 through 61 with a one line for each item with line 61 appearing as: { ______Fencing [See 73.49] } (The dash is for the initials of the person certifying compliance for that individual item.)
INSPECTION PARTICIPANTS:
Initials: Signature: Title: Date:
1)________ ________________________ _______ __________
2)________ ________________________ _______ __________
(Continue this 6 more times.)
I, Name of Inspector, certify to best of my knowledge and ability, this station, Station Call to be under the basic rules and regulations of the United States Federal Communications:
🀆COMPLIANT 🀆NON-COMPLIANT
as indicated in this report. If, “Non-Compliant” I have determined the professional qualifications of the person(s) by my initialed check-mark above. Upon receipt of her/his/their notarized, acknowledged statement of corrective action taken for all items indicated as “P” (Pending) and certified-mailed to the address listed below within 60 days of this inspections, I am authorized to and will issue a formal certificate of FCC Basic Compliance.
Respectfully Submitted,
__________________ _______
Inspector’s Signature Date
Name address and phone number
of the inspector.
_________________________
_________________________
PC: To Station Licensee/Management
Original: On file with inspector’s office
The preceding, for which absolutely no compensation is requested nor will be accepted, is not to be construed as formal legal advice, but rather the sharing as a good faith expression of experiences from over 50 years of proud service to the American Broadcasting Industry by this author and/or any of his associates.
The views expressed by Media Information Bureau columnists are those of the writer only and not of the editorial board of the Radio + Television Business Report or its parent, Streamline Publishing.
