Alternative FCC Inspector Ken Benner’s previous column on alternative inspection certifications drew such a strong response that Benner believes the subject needs to be addressed further.
He writes, “Be assured there is no reason why your station(s), with a reasonable degree of professional management and staff dedication, cannot certify following a careful review of the primary items of which the FCC is most concerned with.”
When I visit a station seeking such certification, I make it clear I am not there looking for trouble.
Rather, my purpose is to see that all staff members realize my visit is to simplify compliance.
This is done by having them understand what is and, most importantly, what is not important.
After this is spelled out, I request a one-hour meeting with as much of the management and staff as possible.
There is no such thing as a “dumb question.” Any question will be most appreciated, especially those I can’t answer.
Why? In such a case, we will both learn something from the reference material I carry, or from one of the individuals who answers a call from the 300-plus list of phone numbers I possess for FCC staffers, fellow contract and consulting engineers, columnists, and friends.
My briefcase contains a copy of the eight FCC Self-Inspection Checklists.
I suggest you hop on the FCC website and print a set for yourself.
These are for AM, FM, TV, FM Translator and Booster, Low Power TV – Translators and TV Booster, Low Power FM, and Class A TV stations.
With these booklets you will have ready access to answer, with documentation, 99% of the questions that may be asked.
For the remaining 1%, my phone list comes into play.
SELF-CERTIFICATION DOCUMENTATION
If you are going to self-certify your station(s), it is essential to create the documentation upon which your certification was achieved.
I suggest this “documentation sheet” be posted behind your self-issued certificate of compliance, should there ever be the slightest question as to how such certification was obtained.
Here’s how you create such a documentation sheet:
Heading: “ALTERNATIVE FCC INSPECTION REPORT FOR STATION(S)__________ as conducted on ______
Then (for this example) using the AM Checklist, prep an 8-1/2” x 17 sheet with 107 numbered lines appearing as:
1_______AUTHORIZATIONS
2_______STATION LOGS/RECORDS
3_______AVAILABILITY(continue with remaining104items)
The line is for the initials of the person responsible for certifying that item. For example, the manager might initial #1&2 certifying proper license posting. #3,4&5 could be initialed by the Chief or Contract Engineer, #16-28 to be initialed by the person(s) involved with maintaining the Public Files, and so on.
Don’t let this process appear overwhelming. A little practice reviewing this on an annual basis will keep everyone up-to-date without spending hundreds or thousands of dollars in broadcaster association dues and legal expenses, in addition to adding up many, many hours of frustration.
Lastly, following the procedure above, provide a line for each of the participants as:
______ ___________________ ___________ ______
(Initials) (Signature) (Title) (Date)
The certificates for reception area posting that I designed more than 20 years ago and presented in person to the FCC Compliance Bureau for approval reads as follows:
Voluntary Alternative FCC-Inspection Program
FCC Regulatory Compliance Certification
(SPACE HERE FOR STATION(S) CALL LETTERS)
On this date, the undersigned, with the assistance of appropriate staff and management, carefully reviewed all items on the applicable FCC Enforcement Bureau Checklists, F0-794, & 1130-A Inspection Reports, 854R Tower Registration, Public File Compliance, Carrier Frequency, Modulation and Power Levels, Required Logs, EAS Requirement, Licensure, Elements of Good Engineering Practices and other areas of FCC Regulatory Compliance after which it was determined:
This Station is fully compliant with all current basic U.S. Federal Communications Commission Rules and Regulations.
Date:___________________
______________ ______________ ______________
(Signatures of those participating in this inspection)
FROM THE AUTHOR: This column is in no way a solicitation for any purchase of my services. I have far more work than I can handle, I am retired, and a joy in my life is lending a helping hand to anyone in need.
RBR + TVBR 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. Benner has more than 55 years of experience providing service to the broadcast industry.
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