Media Information Bureau featured columnist Ken Benner is back with another great column designed to prevent your station’s accounts payable department from writing a hefty check to the U.S. Treasury or FCC in response to a Notice of Apparent Liability for Forfeiture.
Today, Benner is pleased to offer RBR+TVBR members details from his most requested handout distributed over his 23 years as an ABIP inspector.
Where Do I File This?
By Ken Benner, CBRE, NCE
President Emeritus, Coalition For Legislative Transparency (AZ)
This item is by far the most requested I have ever handed out during my 23 years conducting Alternative FCC Compliance Certification Inspections.
I am pleased to share it with you. However, it is not to be considered legal advice. Rather, it is designed to serve as a common-sense, good faith review of past experiences.
This is the most current, up-to-date version.
Suggested File Systems For All Stations
1) THE MANAGER’S FILE is to include management related items, the news director’s files, sales manager’s files, insurance files, employee application files, internal office memos, station correspondence and significant obsolete items previously placed in the public file, such as license renewal applications (following the actual renewal) and other obsolete items from the public files that could assist management in the future such as “Investigative Reports” or “Political Files”. For example, such could be used to train new employees, assist future political ad sales or pursue news item updates.
2) THE PUBLIC FILE should include the 16 (for radio) or 19 (for television) as described in the (FSICB) FCC Self Inspection Checklist booklets. While not required, we have long suggested an additional folder with sheets describing the proper handling of a public file access request such that a new employee can properly such requests. These sheets should have space for the address to mail items requested by phone, charge for duplicating each page. Please refer to page 3, item F to complete all items. Once it has served its purpose it should be retained in the Manager’s File to prove the party requesting access was served properly.
3) THE ENGINEER’S FILE should include all technical reference material, equipment manuals, schematics, maintenance history, processed technical applications that have been implemented and license modified to reflect such; new antenna, transmitter, power changes, tower relocation, radiation compliance certification, the form 854R tower registration certificate, tower painting lighting and outage log, meter calibration logs, EAS activity logs, Annual NRSC-II bandwidth measurements (AM only). Good engineering standards strongly suggest including maintenance logs detailing motor lubrication, air filter changes, details of defective equipment repair, manufacture’s customer services and a comprehensive diary of transmitter site care. (Many xmtr sites we have seen hadn’t been visited for several years. Sad and potentially costly indeed!)
4) THE OBSOLETE-HISTORICAL-SCRAP-BOOK CATCH-ALL FILE should include all other items not required in the above systems i.e expired licenses, award-winning ad copy, other items of historical significance such as first day on-air log, commendations awarded and anything worth saving that doesn’t quite yet qualify for the shredder.
On behalf of my wife, Karen, and I, we hope that this helps your station.
As she says, “Nothing makes life more pleasant than having everything simplified and well organized.”
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. Benner has more than 55 years of experience providing service to the broadcast industry.
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.
