Broadcasters' Desktop Resource

... edited by Barry Mishkind - the Eclectic Engineer    

CircuitWerkes Inc.

From the Editor:

The Current Editorial is located here

Previous Editorials:


The NPRM for AM - Will It Do Anything?

Promises made by the FCC - specifically Commissioner Ajit Pai and Acting Chairwoman Clyburn - were made real with the NPRM for AM Revitalization.

Of course, some of the relief that is asked for by AM operators has been "in process" for well over a decade and a half. The challenge will be for the Commission to actually do something this century.

As mentioned below in our September note (below), the FCC could - and should - separate parts of this proposal and implement them immediately. The ones that require extensive debate could be sub-contracted to the US Congress for the expected eternal inaction.


An issue that should be addressed either directly or within this NPRM - but, again, RAPIDLY - should be a recognition of the RFI issues from consumer products. Especially so since bureaucratic bumbling was again shown with the ham-handed citation issued to a beauty parlor because GE florescent lamps were alleged to be causing interference to an AT&T LTE installation, next door to the beauty parlor.

What about all the RFI from all sorts of products that have caused great damage to the AM stations in this country?  Why should cellular companies - who are reaching for unheard of levels of signal (as low as -130 dBu or more) - be given such deference when the entire AM band is riddled with RFI that clearly violates the Rules? (see comments below from June.)

When will the FCC stop playing favorites, responding to lawyers from large corporations, before stopping to enforce their own Regulations? "Last in remediates" has been the policy for years. Why is it suddenly different for cellular companies?


There is no question that some proposals will be controversial. For example, many commenters suggest - perhaps quite accurately - that pushing FM translators for AM stations is bad policy because it does nothing to improve AM, and merely directs listeners to the FM dial. And that does not address the issues of abuse that will certainly occur as some companies would use the option to extend the nominal coverage of a station, rather than preserve it.

One could call FM translators a band-aid (pun intended) that ends up infecting the wound.

These and other such contentious issues should be separated as soon as possible into separate NPRMs - or however the bureaucratic mechanism has to work - and get on with doing what can be done right away!


We do hope that the new make-up of the FCC, with the newly appointed members, does not return to the aggressively anti-broadcast posture of the last full Commission.

If Commissioner Pai's intiatives can gain some traction, there is possibility for AM station operators to hope for a positive outcome. But, to tie everything to a big NPRM, with hundreds of expected comments and reply comments, there is the big possibility that we will see the same result as in Congress: a lot of time and money spent, but almost imperceptible results. A bureaucracy does not move quickly, unless it seeks to impose rules and raise money.

If you have a strong opinion, this is the time to tell the FCC. It is not hard to file an electronic comment, but it has to be done on time. Although we sincerely hope the process will be split off and some action taken quickly, it still remains possible this will be the one and only opportunity to help AM for some years. We hope we are wrong on this second possibility.

Your comments might make a difference.

What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


AM - Time for Cheering?

The Keynote address at the NAB Fall Radio Show certainly were the words to cheer AM operators. Acting Chairwoman Clyburn delivered a potential present that addresses many of the issues of importance to AM stations.

The question is: Will the FCC now do something - or will they talk this to death?


The extremely well attended session led by Commission Ajit Pai at the Spring Show in April was a showcase for his goal: to revitalize AM.

Panelists related all the problems, from AM audio quality to covering the market to RFI to the hassles of getting anything done at the FCC. Pai's discussion noted, however, that aside from the recent permission for AM's to buy and use FM translators, more than one of the proceedings and requests for relief have dragged on for years - even a decade, while the FCC talks and talks.

With Clyburn seeming to climb on the bandwagon (no pun intented), there may be some reason for AM operators to hope.


If AMs can buy and use translators, allowing them to apply for and get one without having to deal with speculators, for example, is a major plus.

Other initiatives, such as killing off the "Ratchet Rule" and re-defining coverage and efficiency rules, may well permit stations to upgrade, change sites, and implement MDCL, etc, improving the signal for their market and listeners.

There has been some "outreach" to AM stations in recent years, such as the implementation of the MoM modeling method for directional stations and some simplified procedures. But AM needs more.


The best thing the FCC can do is fast track these items - and add to them.

The announcement of the NPRM (Notice of Proposed Rulemaking) will only be of value if there actually is an NPRM with clear intent (dare one hope for a "plain English" document?) and definite dates of action. In fact, it would probably not be a good thing for there to be one NPRM, as that would create the sort of lengthy and complex comments and responses that will take months (years) for Staff to wander through.

Putting out several pointed NPRMs with a short fuse might be best approach, if this is truly a path to help AM operators, not a version of Lucy giving Charlie Brown hope and then pulling the football at the last second.

For example: if an AM station is to have a translator, it must be locked to the AM license and program, limited to 250 Watts, and the contour somehow be limited so that it is not used by a large group to be placed at the fringe of current AM coverage, merely to reach another market. Perhaps the first group of such translators should be limited to the AM transmitter site.

We hope to see quick, substantive action on this. We hope that Commissioners Clyburn and Pai are able to get the legal staffers to bring the NPRM(s) to light rapidly, and fast-track each one as possible.

Commissioners - please let Charlie kick this one right through the goalposts!


What do you think? Did we get something wrong? Share your thoughts:  You are welcome - and invited, yes, encouraged - to do so.


FM vs LTE - Who is Responsible for Interference?

Reports from around the country indicate that as the cellular industry builds out their 4G LTE networks, confrontations with FM stations are increasing.

As this article discusses (including a spreadsheet of potentially problematic frequencies), the problem is basically one where technology is being stretched right to its limits. However, as with many things today, lawyers and politicians wade in where they have no technical experience, only to debate the finer points of grammatical construction.

No transmitter is permitted to interfere with another. Nevertheless, different users have different criteria for "clean operation." And what is clean to one service may not be for a new, cutting-edge technology.

Cellular companies have plenty of reason to have the hottest receive sites they can develop. Not only does it provide better service to customers, it permits spacing cell sites further apart - something that means significant savings to the cellular folks.


But, just because the LTE receivers are able to operate down in the region -130 to -140 dB, which is in the "grass" (internal noise) of most spectrum analyzers, does not mean that FM transmitters are suddenly causing harmonic interference.

In many places stations have co-operated with cellular companies to reduce any problem harmonics. However, the Policy of the "last in" tenant to a site being responsible for interference remediation has been supplanted in some places by bullying and demands from some companies 'to cease and desist from illegal interference with our receivers.'

It at least one case, a cellular company rented space from an FM station, then demanded the FM station prevent any interference to them (one report says it only takes 2-millionths of a Watt on the 7th or 8th harmonic to desense some receivers in close proximity to an FM transmitter - significantly below the levels FM stations are regulated to achieve at Section 73.317).

Different consultants from around the country have already reported that often the cellular engineers come in and make demands based on overloaded, or otherwise mis-calibrated, test gear. Small stations are often at a loss on how to deal with this bullying. They need help and leadership on how to defend themselves.


This is the time for something to be done within the broadcast industry. No matter what, the more the lawyers get into it, arguing over the definitions of "interference," "harmonics," and  "emergency communication," costs will skyrocket. (Sounds a bit like the situation with Patent Trolls, does it not?)

That is why the NAB should take a strong lead to make sure this does not end up with action at the FCC to give more "protection" to the cellular installations. It is clear that broadband trumps broadcast with the current Commission. The existing policy of "last in" needs to be reinforced - so long as the FM station is within the emissions limits set in the Rules.

A very strong and united cellular industry lobby most certainly will lobby for stricter emission limits for FM. The normally fragmented broadcast industry needs to take note and foster a unified response - and educate the individual stations and engineers in the field.

Technology may well improve, but you cannot legislate physics.

(link to a more complete article on this topic)

What to share your thoughts?  You are welcome - and invited, yes, encouraged - to do so.


The New Boss: Same as The Old Boss?

This week President Obama announced his choice for the next FCC Chairman: Tom Wheeler. Mr. Wheeler is a long time lobbyist for the cable and cellular industries and a political fundraiser for the President.
Initial responses to Mr. Wheeler's nomination were mixed. Much of the telecommunications industry was favorable, including the NAB. On the other hand, some noted that Wheeler is in the same mold as Mr. Genachowski, who spent his time preaching "Broadband" and seemed highly interested in removing over-the-air transmissions, especially in the TV arena. More spectrum auctions are in view - and they want to move quickly. (Congress thinks this will be a big moneymaker. On the other hand, the results may well be regretted before too long, especially by consumers, who will be presented ever increasing costs for content.)

Broadcast is in a difficult place. Even as consolidation has reduced the choices - and the energy - expressed on-air, other forms of media are getting more and more attention. The huge to-do over the report that radios were being pulled from dashboards showed both the trends that are on the horizon and the panic that traditional broadcasters have developed, as the audience adjusts to their new choices.

Strangely, broadcast generally continues - with some notable exceptions - in a "woe is me!" mentality, sounding like the victim of a hit and run accident. The truth is somewhere else. As is often stated: "it's the content." With corporations focused on grinding every last dime out of their programming, they took their eyes off the ball: content. While a few hit shows like The Simpsons seem poised for stunning payoffs in syndication, the majority of what is on TV and radio is much more forgettable.

Even when storms and disasters present opportunities to show local communities which outlets really care about the area, far too many stations just let the automation play - or flip the network switch and sit back and watch. "We can't afford more staff" is the usual cry.

It is sort of like driving on threadbare tires. You can do it. You might even get across the country safely. But all it takes is one unexpected problem and you are sitting on the side of the road in the middle of nowhere - or worse.  Putting good tires on a car is essential.

Programming to the community is essential.

It cannot be done by voicetracking from another city 500 miles away. Traffic issues cannot be reported from another state.

Programming must be local and live to energize a community. 

Otherwise, the new Boss at the FCC will be successful in sweeping broadcasters off the air, and helping the cable and cellular folks in expanding their empires.

By the time the public is required to pay for each megabyte of content streaming via their provider, it will be too late.

Broadcasters need to make sure their communities know their value now.

What to share your thoughts?  You are welcome - and invited, yes, encouraged - to do so.


The Sky is Not Falling!

The industry was completely abuzz over the past two weeks when a magazine publisher announced that he had information that "within two years" at least two car manufactuers had planned to stop putting radios in car dashboards. Within five years or so, all of the manufacturers would follow suit.

Radio is "finished!"  Internet connected media would take all the dashboard space.

Don't you see the writing on the wall? The sky is falling!

Or is it?!


There is no doubt that radio is not going to disappear imminently. The sky is not falling.

Several car manufacturers stepped up to announce they had no plans to eliminate car radios. Then, the publisher - Eric Rhoads -  issued a public apology, noting that he had misunderstood what was said by participants at his seminar. There was nothing to say that anything that dramatic was going to happen any time soon.

On the other hand, there is reason for concern.

We all realize that radio is not the same as it was in the 60s and 70s, for example. The on-air wars between similarly formatted stations brought vibrant energy to radio. It was almost as much fun to listen as to work in radio.

Communities benefitted. The news and public affairs programming. The local remote broadcasts. Air staff appearing at schools and service groups. Broadcasters were truly part of the community. To this day, many people remember the announcers and disc jockeys of past years ... men and women, many of whom went on to become well-known community leaders.

Then came satellite delivery, automation - and consolidation..


It was in the 1980s that things really started to change, long before the Internet. The owners, led by the NAB, got Congress to pass the Telecommunications Act of 1985, relaxing the ownership requirements, the Three-Year-Holding Rule, etc. This made stations more commodities than public servants, and station prices escalated dramatically. Station prices went up. Not staff size nor salaries.

Because businessmen were now running radio instead of broadcasters, saving money became the goal. Automation, which could help airstaff make great improvements to the air product, was used more often to replace and eliminate staff. Voicetracking five hours of air-time in one hour was great for the bottom line, but horrid for air product.

"Unlocking" asset value brought about the sale of transmitter sites, diplexing, triplexing, and even reducing directional stations to low power non-directionals as value was extracted from station after station.

Today, it is common to turn on most radio stations and hear satellite delivered music and talk, interrupted by five and six minute stop sets - with 10-12 commercials at a time.

It is no wonder people are taking advantage of the new inputs to their car radios to play their MP3s and podcasts. Pandora, Wi-Max, and other alternative delivery systems are not only being put into action, but appear to be - wait for it - a potential profit center for the ISPs and cell phone companies.


Some think it is too late. Radio is doomed.

True, it is likely radio will never again be the intimate companion it once was - especially so given what consolidation has wrought. (Have you ever been to a studio complex for a cluster and seen a dozen studios in a row - and not one live person? Sadly, this is not uncommon. Have you ever asked a listener about their last experience in calling a radio station on the phone? Enough said.) Yet, that does not mean that radio is dead.

Radio is still loved by many - and not just those who do not own an MP3 player.

The demand for services from broadcasters in the wake of the recent storms, hurricanes, and tornados makes it clear that many people still turn to radio when the power, cell service, and the Internet go out.

Check that.  They go to Analog Radio. (A whole 'nuther story). 

And at least in most larger cities there is a station that still has enough staff to go live and report on a local disaster of some sort. But the workers on the front lines do not control the budgets, and can only wax nostaglic about the "Good 'ole Days" when radio was the heatbeat of  their community. The huge money deals are far above them, and handled by people who have never sat in front of a microphone to entertain or inform local listeners.

There is still time for broadcasters to ensure their audience will stay and not drift off to the alternatives like dash mounted MP3 players and streaming services.

Content is king. Especially local content. It has been - and will be.

Radio may get in a kerfluffle over rash predictions of instant demise. But the wise operators are paying attention.

What to share your thoughts?  You are welcome - and invited, yes, encouraged - to do so.

This response came from Randy Michaels:

I have read much that has been written on this subject.  This is the first article I've read where my response is "I agree with every word".  Good job.

This response came from Jim Jenkins:


I've noted that Eric seems to drift in the direction that if it's not digital, social, internet based radio you will not make it. 

You are right in the history of the direction of radio and that content is king.  We are live radio real people in real time. 

When it comes to stories of local AM almost all of them talk about sports as the prime mover.  I differ in that.  We are music driven.  I don't know sports, don't like sports, and don't have the resourses to put together sports.  The notion is that we are a leader in discovery of both new and old music.  It is picked based on "the WAGS feel" just like Rush Limbaugh and Marth Stewart's programs are based on their insight.  Someone has to choose and it might as well be me.  So far I seem to be able to select stuff and find it resonates with people.  No consultants here.  I didn't buy WAGS to let some Guru program it.

Back announce everything, no mindless liners, every ad alway adjacent to music, be genuine in how you talke about the artist and selection, just be a real person talking to the listener (companion).

This could be done again except that big money and mgt are scared to make a decision.  If I liked the song probably someone else will.  Playing is safe never makes things exceptional.

Jim Jenkins
WAGS Radio
142 WAGS Dr
Bishopville, SC   29010


An FCC Commissioner Who "Gets" AM

FCC Commissioner Ajit Pai seems to have made it his goal to do something about ths sad state of AM radio in this country. This is a welcome position, even as some other commissioners push "broadband" as the panacea for many of the nation's communication problems.

We must first acknowledge that the FCC has much more than broadcast to regulate. From telephone to all sorts of RF, the Commission has pressures from the public, industry, and its Congressional masters to care for the desires of each constituency. In recent years, broadcast has taken a definite backseat to the rush to auction off more and more spectrum for cell phones and Internet transmissions, among other things.

Yet, as the recent Hurricane Sandy and the Winter Storm this week show, when the power goes out, so does the Internet and cell service. Even when "on," social media seems to pass on as much rumor as accurate news. Only broadcast stands out by staying on the air with a signal that reaches the whole market - at least when the station has made plans (read: generators) to stay on the air.


Pai gave a speech this week to the Media Institute that he used to point out the key place broadcast has in reaching the public during emergency conditions. He noted that broadband cannot substitute for broadcast. It can be a complement to enhance broadcast, but it cannot replace it.

Especially in looking back at Hurricane Sandy's aftermath, it was clear to Pai that broadcast was essential, transmitting lifesaving information and alerts, even as other forms of communication faded from the storm effects. It is only the high powered AM stations that have the best signal propagation and truly can give regional coverage - penetrating to even into rural areas. Furthermore, the nationwide PEP (Primary Entry Point) system relies on those Class A AM stations to spread information (including EANs) widely - and will continue to do so, as there is no real reliable alternative.

For those and other reasons, he has advanced ideas for relaxing ownership regulations for broadcast companies, to keep them viable.


As part of his agenda, Pai is organizing a panel to present ideas on revitalizing AM during the Spring NAB Show. (The sessions is scheduled for Monday, April 8th.)

This follows his comments at the Fall Show last year that the FCC should help AM, especially those struggling to stay alive. He suggested some rules could be relaxed and the Commission give attention to positive actions that would help AM continue to be a viable resource in the country - and ready when emergency situations occur.

Of course, an FCC Commissioner by himself - nor even the entire Commission - can accomplish this without the industry responding by investing in the air product of its stations, making them more valuable to the community.

In the past few years, it has become pretty obvious that when storms, floods, or other disasters occur, it is broadcast - primarily AM - that is the shining light in the darkness. At least that is true of some of the AM stations.  As we have noted in the past, far too many stations either have no emergency power or just let the automation run - and are as useful as playing weather reports from last August..

Meanwhile, the difficult economy is the usual excuse for staff reductions, even as corporate big-wigs carry home multimillion dollar bonuses each year.


There certainly is attention focused on broadcast during the emergencies - in many places EAS alerts are noted to have proven invaluable many times. But the industry as a whole continues to push listeners and viewers elsewhere for infomation.

Here is hoping that Pai's efforts will be rewarded with cooperation from the broadcast community to build real content into broadcast schedules. Perhaps the profit margin might shrink a percent or two. But true Public Service will be rewarded by the listeners' and viewers' reliance and respect for their local stations.

Either that or the broadband advocates will continue drain listeners off to streaming audio, WiMax, and other alternatives to broadcast.

... which would be a shame.

We salute Commissioner Ajit Pai's efforts to help broadcast - and especially AM - reach its true potential. This is apparently a Commissioner that "gets it!"

What to share your thoughts?  You are welcome - and invited, yes, encouraged - to do so.


Derecho Storms - CMAS - and Broadcast

We are reaching a key point where broadcasters are going to have to be clear as to where they are going to stand in terms of  public service and emergency information flow in their markets. This is especially true for radio.

The FCC report on communications issues during storms (specificially the Derecho last year) and other emergency events has a good objective - and it touts how good the broadcasters were during the Derecho disaster, especially when feeding information to those listening on battery powered radios. But broadcasters will not like some of the other conclusions.

For example, there are recommendations putting emphasis on boosting 911 reliability, make IP distribution better, etc. etc,

But, we know what happens when the power is out and phone lines are down. Yep. People have to turn to radio - analog radio - to get information and news about what is happening. Yes, there is also a lot being said about the CMAS alerts going out on some cell systems. A lot of people are being "alerted" by strange tones - and even more cryptic messages.

On the other hand, even when the power is still on and TV stations can show weather reports, for example, efforts to bypass broadcast by local officials continue to seem more like job protection and control of information flow, rather than getting key information out quickly to the public.What else can you conclude when local authorities proudly announce things like their use of "reverse 911."


The sad truth is that while the local authorities claim they know best, few discuss:

  1. How many people refuse to answer the phone when they do not recognize the number?  Answer: Too many.

  2. How many people will stop and listen to a robo-call, even if they do pick up the phone? Answer: Too few.

  3. How many people did not get any alert in places - like Colorado last year - when fire burns the phone lines. Answer: Too many.

Broadcast radio and TV are still the only way to get information out to the public on many problems

National Weather Radio does play a part for those with weather radios, but it does not cover all issues - nor are the NWR to CMAS alerts ready for Prime Time.

This was dramatically shown in Washington State recently, when a "Blizzard Alert" was sent out to a lot of cell phones on the systems that are actually running CMAS.

There are only a few problems with this:

  1. The alert covered not just the area of the Blizzard. It also was sent to the entire county, lowlands as well as mountain regions. A lot of the public was just plain confused.

  2. The alert indicated "Blizzard Warning" and "Check Media."  What media?  The SIM card in the phone? A CD or DVD? Or which TV station or automated radio station in the area of the message? There was no indication.

  3. Worse, most of the broadcast stations had no clue what was going on. They had no information, even if the public did tiurn to their radios and TVs.  Many listeners just bypassed "media" and turned to the Internet, which was quicker - and, often, more informative.

  4. And even worse yet: The way the protocols are set, cell phones 100 miles away, in Portland, reported the Warning. What were those people to do? Where to turn?

NOAA and the NWS are quick to point out that they are working on these problems, albeit with grudging support from some cell providers.


Meanwhile, it is telling to read the comment in one of the FCC reports that EAS is mostly for tests, whereas the CMAS alerts are giving vital information to the public.

Of course, stations are required to do the weekly and monthly tests. But, when stations do only the minimum - the RWTs and RMTs - without providing information on local emergencies, EAS becomes less highly regarded by many in the emergency management community. By letting things slide as more and more stations automate, broadcasters are tossing away the opportunity to be of value to their local listeners. Allowing those reports to continue the "EAS is for tests, CMAS is for disasters" mentality is bad.

If nothing else, CMAS alerts do alert people that "something" is happening. Broadcasters have, in many places, no information other than "this was a test." Aside from a few items - tornado warnings are often sent out in soma areas - shortsighted Program Directors and General Managers have banned relaying EAS alerts as "breaking format." In other cases, it is the consolidation and automation of the industry that has "no one at home" to react to incoming information, and too many listeners tune across the dial to find stations just "playing the hits" instead of offering critical information.

The Broadcast Warning Working Group (BWWG) feels broadcasters need to step up and work closer with local authorities. Yes, it will take some manpower, but the other option - to abdicate the place broadcasters have had in dissemination of emergency information - is the worst thing that can be done, even in the midst of the continued cost-cutting at the big chains.


For many of these reasons, the BWWG is proposing a "Two Steps Forward" program for broadcasters and local emergency managers to come together and make the alert system stronger and more informative to the public. Watch here and on the EAS Forum for more information on this program, spearheaded by core member Richard Rudman.

Or maybe you have some ideas on how to position radio and TV as more than "a place to hear EAS tests." 

What to share your thoughts?  You are welcome - and invited, yes, encouraged - to do so.


Another Storm - Another Opportunity for Radio to Be Ready

Bad weather is a pain, no matter how you look at it. However, for Radio, it can be a rare chance to shine - to show the community why they should loyally support their local station. And yet, with the current state of the industry, too many stations have used the old "we lost power" or "we didn't have enough staff" excuses. With planning, any station can be the local Star of the community - and receive many benefits now and into the future.

But the key is planning. It has been said that those who fail to plan essentially are planning to fail. What is your plan?


No one needed an EAS alert to know something big was coming. True, as usual, there was some hype on the local TV and network/cable weathercasts ("the worst ever"), but it was clear for days that this was more than the usual storm.

Hurricane Sandy was advertised for a week as the "Perfect Storm" and the "Frankenstorm." Some of the cable TV networks went into 24/7 coverage. The reports of damage are pretty amazing, especially the flooding in so many areas - so much that not only was power knocked out but houses were washed away and public transport was left reeling.

It will likely take several days - or weeks - for things to get back to "normal" for those areas affected by Hurricane Sandy. But local listeners already know which stations were prepared to serve the community, and which were not. Unfortunately, in far too many cases, there was little of substance on radio, except when they rebroadcast a local TV station (without pictures!).

Radio can do better than that.


The lack of power was expected from a storm of this magnitude. There were many, many reports of "bucket trucks" heading east at the end of last week as crews were pre-positioned for the chore of repairing the electrical grids.And anlmost right on cue: All of Southern Manhattan lost power mid/late-afternoon on Monday. (Some of the TV networks had studio lights going up and down. Others cancelled programs - although David Letterman did do his show ... in an empty theater.) Some reports last night showed as many as 2 million people without power in New York City. Another 5.5 million were without power in 15 states. And that was from a storm that was 1000 miles wide.

And, with no power, cell sites that had power were predictably overloaded - according to Chairman Genachowski, 25% of the cell towers failed during the storm - and then there is the issue of recharging phones. The loss of power pretty much took the Internet down as well. In other words: cell and Internet were not reliable communications resources.

What do you suppose was? (no guessing now!)

With yet another opportunity to shine, it was radio that was left standing - at least where power and/or generators were available -  to be heard. While some stations did totally lose their studio or transmitter sites to the floods, others regrouped using auxiliary or other facilities.


As usual, reports are coming in about some stations that went "above and beyond" in their coverage of the situation, offering information and guidance to those affected in their areas - as well as reports of "not so much." Sadly, a few merely "let the automation play." In many areas, there was nothing of value on the local radio at all. Perhaps you have heard one or more like that.

Portable TVs are rare, especially DTVs, and those that exist have voracious power needs. Streaming a local TV station on a smartphone or table often was more useful than trying to find information on the radio. But that required either power and Internet .. or a working and not-overloaded cell site.

Would it really bankrupt a company to provide service to the community? In many cases, just opening the door would be met by many local volunteers. Even if it were a case of overtime, one week's expense could only hurt a company already beyond help.


It was interesting to read that in an interview with Federal Emergency Management Agency Director Craig Fugate, he directed people to radio (and pretty much analog radio).

Fugate said that when other sources go out, "radio is oftentimes the way to get those important messages about what's going on in the local community." He mentioned battery-powered and/or hand-cranked radios as "something you don't really think about anymore ... " 

On the other hand, Hurrucane Sandy is a demonstration of why we should think of those radios, as well as solar-powered models (I do not think we have wind-powered consumer radios as yet!)... and think about it now. Stations should tell their listeners about them! After all, what good is even the best news team if there are no radios with power out there?

Truly, stations should plan for the next Hurricane/Flood/Earthquake/etc, now - not waiting until the next threat arises to scramble to put a plan in place. Some suggestions are here. More are being added. But a quick checklist is easy:

  1. Have generator power available. (without power, you are just another victim!)

  2. Have a backup transmitter and transmission path set up.
         ... even an exciter and a coathanger is better than no signal at all!

  3. Have a way to feed the transmitter, even if the studio is lost to the emergency.
         ... it could be a real remote broadcast.

  4. Make sure the staff knows what to do in an emergency, and how to contact one another.

  5. Have sufficient water and food on hand or quickly available to keep staff going.

  6. Have a plan for staff to sleep if necessary, including site security.

  7. Remind listeners that they need to prepare too - including emergency radios and lights that will run with the power is out.


Once an emergency is over, it is understandable that there is less pressure to plan for the next one. But use this opportunity to show your listeners and neighbors how important it is that they think ahead, even if only in small steps.

Some people have already put together "Go Bags" in the event they have move fast. Key documents, money, radios, lamps, food, and water, etc. are in a centralized location. Your station can help people to plan to be safe and secure. Do it for yourself. Do it for your community.


What do you think?

What to share your thoughts?  You are welcome - and invited - to do so.

BTW - We have heard that almost every station in New York City went down as Hurricane Sandy arrived. Some of this was due to flooding - as at WINS (1010) transmitter plant in the Meadowlands. WINS was said to have transferred their programming to an FM sister station.

With the explosion of a transformer site, lower Manhattan lost all power. A few stations set up from their transmitter site, like WOR, and many others simply went off the air - like the Clear Channel cluster. (There was a video almost immediately on  YouTuve, showing a dead cluster.) But as time passed, either the clusters managed to get their generators going, moved operations to another location, or had power returned. The biggesst on-going problerm was access -  the extreme flooding in places like lower Manhattan (all the subways and several tunnels were filled with sea water) also prevented travel and access.

At least one station was reported to be broadcasting from the basement in the home of their Director of Ops & Engineering - showing the inventiveness of station staff!

Clearly, even in the #1 Market, a lot of stations could do better in terms of planning.


The EAS Clock Has Run Out. EAS is Fixed!

Yes the 180-Day Clock - which became a 455-Day Clock - has run out.

The FCC now requires all stations to have a compliant CAP/EAS receiver on line and operating. The FEMA did bring their IPAWS OPEN* server on line and has conducted several dozen successful tests (along with a few that failed - but that is what tests are for, after all).

If the President urgently needs to talk to us he now can do so immediately through the EAS.

Well, not quite. You really did not expect that did you?


First, over 1000 stations missed the deadline. We can say this with some authority because the manufacturers have reported a backlog of over 1000 receivers, some of which may not be delivered until September. For listeners to those stations, any national emergency will need to wait.

Secondly, one manufacturer seemed to play "chicken" with the deadline. Users had to wait until just before the deadline to get  correct software to receive the CAP materials. White knuckle time.

No EAS is not perfect. By its nature of partially a mandate on broadcasters and a voluntary thing for Emergency Managers, it cannot be perfect. Add to that the FCC's failure to get the full Part 11 rewrite out to the industry, the increasing automating of more dayparts, the "loopholes" that do not require local EAS on many stations and translators, and the continued audience erosion to streaming and podcasts, and the process of getting emergency information out is harder than ever before - even with NWS now sending CMAS alerts to equipped smartphones.

Fortunately the industry has a reputation of turning its ears - if not eyes - on real emergencies. At least the full-service stations that remain often will focus quickly on any local emergency, with information and fund-raisers targeted to helping their market.


Now that we are in July, what is happening with EAS?

A lot. In addition to the continuing shakeout of the CAP systems - a number of states are running or starting programs, some with aggregators - state and local EAS committees need to rewrite their State Plans and submit them to the FCC. Efforts to encourage better cooperation and participation by local authorities continue as well. Richard Rudman has written a good piece on exactly where things stand.

Not only does the FCC need to bring the Part 11 rewrite to light, but the CAP/EAS manufacturers need to provide better information and displays to meet the needs of broadcasters - without requiring operators to navigate an often confusing series of browser screens. 

For those who have - for whatever reason - delayed installing their CAP/EAS box, the FEMA has agreed to continue sending their RWTs on Mondays during July. Nothing is promised after that.

We hope the FEMA will do at least a monthly test of the system with some (perhaps rotating) code. All broadcasters - who are used to split-second timing - can do now is wait. Unfortuantely, the reality is that few things move fast inside the Beltway - except for leaks. 

But for those who have been waiting to see some of the EAS's potential develop, we are getting closer.

- - -

* IPAWS OPEN = Intergrated Public Alert and Warning System - Open Platform for Emergency Networks


Leonard Kahn - Wrathful No More

There is a lot to say about the life of Leonard Kahn, who died earlier this month in Florida. A brilliant, eccentric, sometimes combative, sometimes reclusive man, Kahn certainly left his footprints on broadcasting. More material on Kahn is posted on this page.

Kahn held literally hundreds of patents. The Symmetra-Peak, AM Stereo, PowerSide, and CAM-D digital radio are just a few among the host of inventions from this prolific man. Yet while many called him the "Father of AM Stereo," others point out it was his legal battles that all but doomed the transmission mode.

Kahn could be very pleasant and accommodating to his many fans. Some attributed this to his wife Ruth's influence. On the other hand, Kahn could be very hard to deal with. His website was called "The Wrath of Kahn;" he was known to turn on people who did not agree with him - and he could be very litigious. He would even, on occasion, announce that he would only sell his products to companies he liked.

His wife's death in 2005 left him quite lonely and sad. Over the ensuing years, Kahn had battles with a number of companies and government agencies - including battles and lawsuits with the City of New York over his sanity and money. For the past few years, he surfaced in Florida, but apparently not under the best of circumstances. A web book, Pro se, on purports to follow some of his battles and explain his viewpoint. 

At his death, Leonard Kahn was 86.

- - -

We'd like to hear your thoughts on Leonard Kahn. Please share your experiences and comments.  Read the comments of others right here.


Harris to sell Broadcast Division: Is it Time to Panic?

The industy and Internet is buzzing with the announcement that Harris is going to sell off its broadcast division.

Among the larger concerns: if someone buys a Harris product now, will there be service and support for it later? If you are buying a $50,000 to $100,000 (or more) transmitter, or even a lower-priced model, you do not want suddenly to find it impossible to execute a repair job because you cannot get the support you need. Think Omnitronix, as a prime example.

Fortunately, Harris Broadcast is not Omnitronix (or LPB). They are part of a major corporation that does business around the world in a number of areas. And, to be sure, nothing is going to happen tomorrow. Indeed, the company has been shopping the Broadcast Division around for quite a while now - without any takers, except SCMS taking over part of their retail lines a few years ago.

Harris has a great reputation built on years of transmitters and studio gear. The DX series, along with the Nautel Ampfets, essentially caused Continental to abandon AM altogether. They also have had some popular FM transmitters. And they sold a lot of gear to the TV folks, both transmission and studio, during the HDTV upgrades..

Plus they have some of the best design engineers in the industry there.


Still, some folks are uneasy about the whole situation..

Surfers ride the wave ... and sometimes they wipe out.  Is this what happened to Harris? Perhaps. Harris did ride a large wave with the move to solid state radio transmitters, the HD Radio, and the HDTV conversions.

But in the last year or so, that wave has reached and passed it peak, and the ride has not been real good of late. Hence the announcement of putting the division up for sale. However, given the likely price tag - and the state of the industry - is Harris a good "buy" for another company?

Problem #1: Harris makes a lot of money from Government and Satellite operations. Comparatively, broadcast is a much smaller piece of pie, especially if you take out the high power and shortwave sales in foreign countries.

Problem #2: Corporate profit levels. In broadcast operations, the margins are much smaller than in other areas. Especially in Broadcast. In fact, sometimes it has been the "poor step-child" for that reason.

Problem #3: Solid State. Yes, the very thing that drove the replacement sales for tube transmitters has kept many owners from buying anything in the past few years.

Problem #4: Management. In the race to stay relevant in the corporate world, Harris has become known for discounting their products to end users. After all, you have to keep the manufacturing line working. This has resulted in what we often call an "accordion" company. That is, they bulk up with staff, sell a bunch of product, then lay off a bunch of people. Too often, that has included the sales staff. Relationships with customers suffer. That may or may not be as true on the TV side, but it is a certainty in radio.

Problem #5: Support. Harris has long been known as the place where calls to support are met with: "no one has ever reported that problem before." Manuals that do not match the delivered gear. And worst of all: the ending of support for products found in many stations - especially when finding and stocking the parts gets "difficult."


Few companies are going to want to buy into all that, even if the TV side has been making money of late. The direct competitors in the US have their own FM lines and most have solid state AM transmitters. With the existing thin margins, what company can afford to house two separate lines of transmitters?

On the other hand, if the price is right, perhaps we will see one of the major consolidators seek to buy off the radio division. While one might think that having a captive transmitter company would be odd, it is already true in automation and traffic software, among other items.

Furthermore, a strong commitment to true world class tech support (read: Nautel, Continental) would go a long way to make the concept palatable, even to competing companies.

And, with the current sales balance being largely international, it might not even be a huge impediment for Clear Channel or Cumulus to buy the radio division. Perhaps Comcast/NBC for TV? Harris Corp. says there is interest from somewhere.

Regardless of whether Harris Broadcast sells quickly, slowly, or in parts, the truth is that the broadcast industry is changing.  With the most current technology, borders are being broken down and broadcasters can choose from the best of the world's makers. We are going to see more changes coming, both from domestic and international manufacturers.

Harris' products - while not perfect - are certainly among the top rankings.

Again, we will not see any major changes for some time yet. But this will be interesting to watch - and certainly will have ripple effects on other parts of the industry.


What do you think?

What to share your thoughts?  You are welcome - and invited - to do so.

A Response from Bernie Wise, President of Energy-Onix

"Here's one transmitter manufacture response to Harris' Action!!
Reference is made to your recent announcement in which you indicated that Harris planned to reduce their domestic Broadcast Communications activity.  This is a tremendous loss for the broadcast industry.  Harris has been the major innovator in the radio industry.  If you know of any RF design engineer who has a interest in working from the Upstate NY area and whom you recommend., I would be pleased to hear from them.  Our industry cannot afford to lose the Harris technical capability."

Bernard Wise, President
Energy-Onix Broadcast Equipment Co., Inc.


Hitch up the Wagons, It's NAB Time Again!

If you call over to virtually any manufacturer these days, they are frantically getting their NAB plans ready, trying to put the finishing touches on new gear, buiilding and packing the booth displays, getting the hotel and air reservations going, and much more.

Perhaps you may not have given a lot of thought to the amount of money and manpower that is involved. It is enormous. For many of the vendors, you are talking hundreds of thousands of dollars.

In this day of the Internet and electronic media, you might ask "Why should we go to Las Vegas for the NAB? I can get the same information on the web."

Actually, the answer on this one is easy: There is no better way to see the equipment you are buying - or will be buying - and have a hands-on experience with the gear, get quick answers to your questions, and meet the people who make and service the product face-to-face. Many products are displayed powered-up on the floor. And as you look at it, and feel it, you can ask the questions that come to mind. You can get spec sheets. You can make acquaintances who will help you should you need field support.

In these days of budget hassles, you might not think that is important. However, those with past experience at NAB will tell you that over the long haul, they saved more money than their trip cost. Sometimes, just one tip mentioned by an engineer on the floor can save tens or hundreds of thousands of dollars in savings on new construction or maintaining your current gear for another year or ten.

Just like the line about being careful with V1.0 of anything, the same is true for brand new broadcast gear. By developing a close relationship with the company you chose for supply, you will get up-to-date information and tips about how to keep the unit running - and to catch any problems that have been found to develop. After all, things do happen with the thousands of parts in any piece of electronic gear.

Would you rather find out that a run of capacitors was found to be bad because your friends at the manufacturer told you - or because something in your program chain to antenna failed in the middle of the night?

Las Vegas as a city is different that it used to be. That may be good or bad, depending upon what you are looking for. The city has borne a heavy load from the housing bust, even seeing more famous Strip hotels (the Sahara, this time) close down. The Las Vegas Hotel (their contract with Hilton ended, and was not renewed) still stands next to the Convention Center, but the new name does tend to show that some things are changing.

Yes, there is still a lot of good food, extravagent hotels and shows (if you've not seen one of the Cirque de Soliel shows, you should budget for it. They are not cheap, but they do "wow" the audience), warm weather, and ... may I mention? ... the Annual Lunch Gathering.

This will be the 20th straight year we have met up at Lunch on Tuesday at Noon, over at the Riviera. Lots of folks have met and developed friendships there - and we would love to see you, too. Here is the info.

Some folks relate there are good air/hotel packages. There are some good prices on the NAB list, there are other hotels even cheaper, if you have a car or are willing to walk a bit. Food is rarely a problem, although the days of the $5 prime rib dinner are gone.

All in all, you will find that the benefits are worth making the trek to Las Vegas, especially if you are planning any pirchases this year.

We hope to see you there!


Site Security - West Virginia Starts 2012 With a Good Idea

We have often written here about the increased need to pay attention to site security. In recent years, the combination of reduced manpower which resulted in fewer visits to transmitter sites and rising copper prices has led to a persistent problem: theft of electrical and ground system copper and air conditioner coils.

Just this week, KPUL in Daytona Beach, FL was knocked off the air for about a day, caused by the theft of about 50 feet of copper. This was the third time the station was hit.

Stations are wise to increase security arrangements, from fences to cameras, to other surveillance methods. But the short time it takes to rip out part or all of a ground system makes it very hard to catch thieves. Utilities have major problems, as well, including the occasional burnt thief.

Worse, the relatively low value of the scrap - perhaps 50 pounds of copper will bring only a couple of hundred dollars - is usually a misdemeanor, causing law enforcement to not make it a major priority unless someone actually dies. 

True, many places now have laws where sellers of metals need to fill out forms and show ID, perhaps even leaving a fingerprint. But this actually causes more hassle to the honest metal dealers, and the money involved and the fines are relatively small enough that the bad guys pretty much continue as they have been. Of course, that does not even consider the cost of rebuilding a ground system.


Of course, no single solution will solve all of this. But a West Virginia legislator has come up with a plan to try to discourage some of the thefts in the first place and not unnecessarily punish any of the small businesses that handle scrap metals.

With 40% of his state within 30 miles of a state border, it is even more complicated for West Virginia businesses, utilities, and cities to catch metal thieves before they are in another state. In the meantime, 911 services, EAS services, and emergency phone services can be disrupted just when most needed. In fact, in recent months, the Governor of West Virginia has had his phone service interrupted 11 times by metal thieves.

Therefore, Delegate Gary Howell, R-Mineral is to introduce a Bill this coming week that makes the theft of metals like copper from a city, utility, or broadcast facility a felony. And it is not the metal itself that is the focus: we spoke with Howell, he points out the "sabotaging an emergency service with the intent to steal" is the felony. His Bill would make the thieves liable for a 1-10 year prison sentence and up to $10,000 in fines.

Howell says "they don't have to succeed in actually carrying off the metal to be guilty of sabotaging 911 service or fiber optic cables or ground cables. Just by tearing up the infrastructure, the damage has been done."


The Broadcasters' Desktop Resource commends Delegate Howell and calls on all broadcasters in West Virigina to learn about and support his efforts.

Beyond that, it is certainly worth working with your state broadcast association to see how laws that might help reduce copper theft can be supported - as well as laws that deal with another issue of damage and liability: BASE jumpers. Usually prosecuted only as trespassers, BASE jumpers can not only be injured - as seen in the Washington DC area last month - but they can easily disturb or destroy antennas and feedlines, taking stations off the air. Heavier penalties than currently exist should be in place to try to reduce this problem as well.

The BDR will continue to highlight these issues and publicize efforts to combat the problems. We welcome your input about what works in your area, as well as tips about successful ways to secure and protect broadcast facilities.


What do you think?

What to share your thoughts?  You are welcome - and invited - to do so.


Wrapping up on 2011

2011 is gone. There is no more worry about getting things done this year. Time now to put your 2012 plans into action.

Of course, as with any year, it is sometimes instructive to look back and see what lessons we learned - and what we need to change in the next year's operations.


No, Broadcasting has not gone the route of the buggy-whip or the hand-crank telephone - yet. We are still the one resource that people have when they need to find out what is happening - at least when the automation is not running.

Broadcasters have a unique opportunity to affect discussion of local needs and problems. They can reach people as no other medium can.  And the examples of how some stations like WEBO fought to stay on the air during emergencies like the floods this fall show how vital broadcasting is to a community. After all, when the power is off, there is no Internet! (Unfortunately, there were other stations with no generators - or with owners who "couldn't afford" to bring someone in during an emergency on a weekend.)

Moving into 2012, the industry has the opportunity to remind their communities why they are so important. Who knows? Maybe it might even help when the station needs some zoing assistance....


Some changes are in the air. Two new FCC Commissioners. A couple of new department heads. A lot of initiatives that sound good. Let us hope the FCC in 2012 finds the time and energy to help broadcasters do more than sell off spectrum.


Anyone hoping the push for consolidation would slow was disappointed. As Cumulus devoured Citadel (which in turn had gotten indigestion from eating ABC too fast), more jobs were lost.  And if that were not enough, we are seeing more and more live air  positions eliminated.

Whether or not you feel that during an economic recession as we have had that Job #1 is to reduce expenses, the result is that more and more studio clusters are vacant most all of the time. With Internet streaming and other options available, it does seem odd for many stations to cede local content to the streamers. And it is not exactly inspiring to see a few people making multi-million dollar bonuses, while thousands have their radio career abruptly killed.


As anyone who has been awake knows, 2011 was the year of the first National EAN test in the history of the Emergency Alert System (EAS). And, depending upon your viewpoint, it was a success or a failure.  But isn't that like most government programs?

If the goal was to grab the programming of virtually every station in the country, it was a success. Aside from some pockets, the EAN was distributed nearly everywhere, horrid audio included. While we knew within a few minutes of the test that there was a loop in the conference bridge used to feed the PEP stations - and even where the problem originated - it took the FEMA three weeks to tell us there was a problem. The last minute moves to change the length of the test and to provide Internet reporting on the test was also flawed.

Although it only took 15 years to have the National EAN test, the last minute dance caused some confusion that should not have happened. But, really, it was the first time. We probably need to give a Mulligan on it. 

In the weeks since, we have seen the CAP server go down for almost a week after having announced that they would be sending weekly tests to EAS receivers with the right software. When contacted, FEMA said there was no problem. But suddenly, the CAP feed to stations returned.

Perhaps the real question relates to the future of EAS. What do stations want and how does that compare with the government's plans? Given the rather unbalanced "required participation" versus the "please cooperate" request to EMs, more work is needed. The recent effort to require CAP certification for EMs wishing FEMA moeny is a good first step.

The FCC's latest review of EAS was just published in the Federal Register. However, the long awaited Part 11 rewrite itself is still awaited. Let's hope it comes soon, and does more than generate revenue for the Enforcement Bureau.


Despite the excitement about increasing the HD carrriers, it doesn't seem a lot has happened, other than many stations abandoning their digital transmissions when parts break. Some car radios are being touted, but whether they will prove a success is another matter.  NPR is the big foundation holding HD from being totally irrelevant. And why not? With all the free steaming on the Internet, what good is a secondary channel with a jukebox on it? NPR at least uses the channels for solid programming.


Despite the heavy media attention given to specific dates proclaimed by one of the religious broadcasters, the world did not end in 2011. Twice. Or was it three times?

And now some will tell us we have to spend  time this year worrying about 2012 being the end of the Mayan calendar and hence, the end of the world.

There is no question that the economy is in bad shape, and despite the politicians telling us they know what to do, people seem to be more and more convinced that things will not improve for a while yet.

Perhaps we would be better served if we all just took a moment to work on our little corner of the world, and exhibit the qualities that promote the peace, kindness, and morals that bring people together, rather than promoting the political and social divisiveness we see around us. Some of us do believe the God has a timetable to end a system of things. But, until then, each of us can take personal responsbility to do our best in treating one another. 


Thanks for being part of the BDR in 2011.

We are thrilled to note that over the year 2011, our number of unique visitors has jumped considerably. We owe our thanks to you and those to whom you have recommended the BDR. We plan to continue to provide more of what we have been doing and add some new features this year. Your comments and suggestions of what we can do to better serve you are more than welcome.

Finally, here's looking at 2012 and we hope the best for you and yours in the coming year!


What do you think?

What to share your thoughts?  You are welcome - and invited - to do so.


The Test That Took 15 Years

Wow, did we have fun yesterday?

FEMA has said the first ever National EAS Test was a success. No ... stop laughing! Think about it. It was only a test. (Commenting on "what if?" is not helpful unless you put into practice the lessons learned from the test.)

That said, there were disappointments. Yes, the audio was horrible. (Discussion of why, and audio samples are here.) But realistically, what should we expect from the first test of the entire system? And, yes, there is a lot to be sought in terms of improvements in the reporting system (those Web Forms). But it was the first time the entire national system was tested. And even tests with failures are good and useful tests.

Sure, we could hope for crisp, clean audio, voiced well, and containing good information. But even if the audio was something we would normally be ashamed of, if it were our doing, the EAS boxes generally did what they should do: they opened up and printed out the information from the header bursts. They passed audio (of a sort). They took the EOM (in most cases) and shut down.

As to the Web Forms, some folks at the FCC made the effort to let us know that information, not enforcement, was the goal. Still, they could have spoken to broadcasters a bit, and much more quickly addressed the many questions that came out of either imprecise or overly precise instructions. Efforts were made. Perhaps not enough. But it was a test.

Overall, if you really are honest about it: for a first test, all of that is not really so bad.


More than a few folks have commented that the EAS system should have been tested from end to end 15 years ago. In fact, several of them have predicted many of the problems we saw displayed yesterday.

OK, fair enough.  We cannot go back and test in 1997 anymore - unless Dr. Who shows up. So, let us move on.

That said, we got to see a new problem ... one for which the solution should be simple - if the federal agencies will just stop mandating things and start listening to broadcasters. The existing system was already in danger of failure in 1997, and in many areas, little has been changed in 15 years.

Broadcasters have told the FCC for years how the system could be improved. Generally, it had a very low interest level, except at the Enforcement Bureau as a revenue generator.

Perhaps this test will be the catalyst for real change.


Actually, the next steps are simple.  Let the feds spend their time working on their feed and procedures. The interacgency turf wars and finger pointing needs to stop. We have complained often that for federal communication agencies, the FCC and FEMA do not communicate very well. Often it is the need for many levels of manager and lawyer to vet every pronouncemnt. This has to stop!

FEMA: Please ... stop the web broadcasts and piles of paper plans. Develop a system to deliver good clean audio to the PEP stations, the national news networks, and whomever else you want to talk to. Leave the rest of the system alone.

FCC: PLEASE deliver changes to the EAS Rules that solve problems, not merely raise more questions. Talk to broadcasters, and see how the existing Rules are completely at odds with how many, if not most, stations operate.

FEMA/FCC: Most importantly, do something. Talk to your Congressional masters. Solve the problem of mandated operations by broadcasters coupled with "voluntary" operations by emergency managers, state officials, etc. Broadcasters do not need a Governor's Override to allow more political speech on the air. When emergencies occur, one of two things happen:

  1. Stations stop programming and devote themselves - people and resources - to air emergency infomation.

  2. Stations continue to play the automation until the power goes out.

If you (federal agencies) want to do something to make EAS truly useful, you will go back to your Congressional masters and solve the problem. Help those broadcasters who want to serve their community. Relieve those who do not; put the licenses elsewhere.


But there needs to be work at the other end of the system. The LECC's and SECC's need to ensure that their areas are working properly during the existing test schedules. 

This is not too hard. Some of the states already have, in place, regional systems that allow the SECC to "see" if all stations are online and ready ... or if one or more is not able to receive an alert.

Better audio paths, with fewer STLs, audio processors, and clippers in the path, would go a long way to solving issues. Why cannot we use the NPR satellites or affiliates as a primary national and/or state source?  Most television stations are ruggedized and have redundant power. Why can we not have one of the digital carriers used for EAS distribution in local areas? PBS stations are often owned by state and local entities. Why should they not be a hub for information?

Of course, this goes back to the nature of LECC/SECC in the pecking order. It is largely volunteer. Another unfunded mandate. The FCC needs to work with other agencies so the burden is not on broadcasters alone - with potential fines as the whip. It will take a lot of cooperation in DC to bring about an environment where the national broadcasters are able to have the tools they need to do the job.

In fact, if the FCC and FEMA truly want to ensure a robust, viable EAS, they could do a lot worse than use some of the budget that produces web broadcasts, paper chases, Web Forms that take hours to figure out and, instead, provide a national grid of available audio and EAS receivers. Take the financial and equipment budget out of the stations' hands, just as FEMA now does with the generators and spare transmitters they install at PEP sites.

It would not cost as much as all the regulatory issues that are now happening.

It is clear, we need another test before 15 more years pass. Why not make FEMA's feed, with a Test code NPT (National Periodic Test) every quarter or six months, part of the testing? Certainly it would be better for the system than the compelely useless Required Weekly Test that really proves nothing more than automation can start a test!

And then, we might just get clean, clear audio and instruction upon which stations, listeners and local EMs could rely.


What do you think?

What to share your thoughts here?  You are welcome - and invited - to do so.

Richard Rudman Responds:

Barry - You have covered a lot of ground and given a lot of EAS stakeholders a lot of food for thought and action in your EAS Editorial.

It is still too early to chart out a precise plan of action for all concerned, but of one thing I am certain. We all should be working toward getting away from SAME EAS and implementing CAP with non-Internet reinforcement, wired and wireless. As you know, Comments were filed with the FCC to that effect as part of the FCC's looking at the Part 11 rewrite. The ball is in the FCC's court to respond to what was said.

My prediction: Forces arguing to stick with SAME EAS will be met with more opposition as test results are assessed. I am hoping for that transition to happen in my lifetime. For anyone wondering how old I am, contact me off list. :-)


The Communications Commission that Does Not Communicate

Here is hoping we get *something* from the FCC today to clarify the questions about the web forms suddenly released last week for the National EAS Test. As of right now, we see nothing new on the site.  Like you, we are a bit annoyed.

Before anyone starts: there are some honest, sincere people at the FCC. They do try their best to help broadcasters.

But there are also politicians and the sort of bureaucrats the British call "Jobsworths"  (as in "I could help you, but it is more than my job's worth"). It apparently requires one of these Jobsworths to "bless" the information everyone has been waiting for before it can be posted - lest our collective FUD* be reduced before the absolute last moment. That is largely why, time after time, promised information does not appear or is excessively delayed for no apparent reason.

One of the good guys was our source for the information that there was going to be clarifications on the FCC Web Report Form. He was aware the issue was being worked on last Friday and the info should have gone up on Monday. For some reason, someone up the chain did not think it urgent to approve the clarifications. So, the guys on the line were subject to countless phone calls and emails asking for information that should have gone out.

Then you have to remember, the upper levels of the FCC have repeatedly shown they do not have any sense of urgency. We could get very cynical and comment on a certain "disease" that seems to afflict government agencies and employees that have never worked a day in the industry. But that does not help anything. It only reinforces the feeling by many that the EAS is

It does not help stations to understand what to do.
It does not answer key questions about the upcoming Test.
It does not respond to concerned and interested folks who want to help.


It does not tell us what Part 11 changes are coming.
It does not show any clarity of how and when CAP is really going to happen.
It does not give us any confidence that there will be attention given in future to improving the situation.

Is it no wonder that many stations - especially those with multiple station clusters - have already decided to file a paper report on their EAS Test experience and forgo the craziness of this web form?

About the only thing left is to wonder how close to the Test the FCC bigwigs will actually permit posting of the clarifications.

Right now?  That would be a good move!


What do you think?

What to share your thoughts here?  You are welcome - and invited - to do so.


*FUD = Fear, uncertaintly, doubt


Thanks, Alaska! 
The Upcoming EAS Test

(This editorial is from Richard Rudman. He saved me from having to write this, as I could not do it better.)

We do EAS tests not only to find out what went wrong, but to also to find out what went "right." National testing of our last ditch federal level public warning system must be done. How well we do that testing, how well the tests themselves are originated and, especially, how the audience perceives and interprets them, are challenges that must be addressed by both broadcasters and our FEMA stakeholder partners who must originate these messages.

Preparing Alaska for a test is one thing. Preparing the nation needs much more thought and discussion. First, we have to ask ourselves if running a nationwide live code test using the EAN is a good idea, or not. Instead, should we not have a way to test the presidential level of EAS without using the actual code the President will be using if a real EAN is issued?  And, what are the differences in doing a live test with the EAN message for TV/Cable, and doing one for radio — what some of us refer to as the EAN "user experiences"? That question has been answered. A first-ever live code test is a needed benchmark at this time.

The 2011 Alaska live code test did produce a lot of information that we can all benefit from. FEMA has an EAN Test Toolkit that contains information to help prepare the national visual and aural audiences for such an event. Alaska’s plan apparently worked. However, what would a plan look like for the entire USA?

Alaska’s broadcasters did what was asked of them, and what was asked of them is already covered in the FCC’s Rules.  The user experience, i.e. audience perception/reaction, is different for the visual audience and the radio audience.  Alaska audience reactions have been studied, and have been a big help to FEMA in preparing their Toolkit.

Here are some user experience issues I noted from the recorded test at the link at:

  1. Origination Issue One: The general public does not know what the FEMA Operations Center or a live code test are. The TV audience had a clue to what was going to happen. The radio audience did not. We have to make sure our state broadcast associations as well as broadcasters do their best to either create or use promotional material that needs to be aired and repeated often before November 9, 2011.
  2. Origination Issue Two: The audio test message was read live. Again, visual audience experience would differ because of visual clues they get that are not there for the radio audience, or for the sight-impaired audience. Hopefully the folks at FEMA will pre-record the test message, and put in place a procedure so any real EAS EAN’s will be pre-recorded. My two cents: Any EAS message should never be ad-libed.
  3. Origination Issue Threer: The text-to-speech conversion was flawed. Another personal opinion based: Text messages for all EAS events, including tests, should be previewed to make sure text-to-speech conversion works properly.
  4. Origination Issue Four: While the audio is reasonably clear, and certainly an improvement over the 2010 test, tones and hum still made the test less than broadcast quality. If this is the way that the national test EAN will sound, distractions do not add reassurance or clarity of communication to the user experience. Will the radio and sight-impaired audience be thinking about "technical difficulties" and not concentrating on the message itself?


The legacy Primary Entry Point (PEP) technology that delivers presidential warnings to us is based on classic EAS technology that we implemented in 1997. Until this changes when the Common Alerting Protocol (CAP) takes hold, the EAN user experience for visual and aural audiences will not improve. This has profound implications for a diverse audience.  This is a key justification for a benchmark live code EAN test before we implement the CAP.

While we in the broadcasting community may know that real use of this particular live code would only happen if regular means for the President to talk to us are not available, the majority of the public does not. There will be calls to PSAP 911 centers! Promotion, Promotion, Promotion…

Because of the "capture and hold" nature of the EAN code, broadcasters (under present rules) are both not able and are not supposed to do anything to change or interrupt what is being aired while the EAN message is being aired.

There are audience language issues as well as audience factors for the visually and aurally impaired that need much more thought and work. I am sure this first live code EAN test will help point these out for mitigation.

Finally, our testing of the EAS should help expose gaps and weak links in the EAS distribution infrastructure. Building and fixing that vital infrastructure is vital to the integrity of our national public warning system and deserves not only attention, but dedication by government agencies at all levels who have the legal duty to warn the public about protective actions they need to take when bad things happen.

Richard Rudman
The BWWG (The Broadcast Warning Working Group)


Earthquake? Hurricane? Who Are You Gonna' Call?

This week is going to be remembered on the East Coast. First a rather unusual earthquake rocked places from Carolina to Vermont and out to Pittsburgh. Then Hurricane Irene started its run up the coast.

In a number of places, the limitations of the telephone network became instantly apparent. Since most telephone companies only build out for a peak of about 3% usage, any time there is a large panic - or even a crowd - service bogs down. Some cell providers will bring portable cells to some sporting events and conventions, but reports were that in some areas, it took as much as an hour and a half to get a call through. And that was with power. Remember the NE Blackout about six or seven years ago? Cell site batteries ran down and an hour and a half would have been wonderful. Actually, service was non-existent.

This is nothing new. Back in the early 90s, when the Internet was just taking off, phone companies discovered how modems could quickly tie up a large part of the available services, as they stayed on line for hours at a time.

Worse, the text messaging that went on displayed the lack of information many had, the anxiety evident, and the huge amount of mis-information. Some "tweets" missed the size of the earthquake by two full magnitudes, others spread rumors such as the Washington Monument was leaning and ready to fall, and undoubtedly the "chatter" caused panic and problems for first responders.


Meantime, people who were close to the earthquake and reeling from its effects, or hundreds of miles away and wondering what happened, had a source of accurate news and information. Of course, we mean that ancient method of communication: broadcast!

During the earthquake, a number of stations turned off the automation and went "wall to wall" with whatever ionformation they could get from the emergency managers in their area. People could learn what was happening, and even if they could not get instant satisfaction of calling their loved ones right away, they could learn that damage was very limited and few were even injured.

Broadcast - one to many. The most efficient means of mass communication.


So, with Hurricane Irene heading up the coast as this is being written, we can be sure that listeners and viewers will be turning to broadcasters for up-to-date weather news, as well as evacuation and other public safety information.

If your station is on the East Coast, we sincerely hope you are prepared to serve your community during this upcoming event. Is your generator ready in case of power loss?  Is the staff ready to react,  knowing who to call for current information? Are there provisions in case the staff cannot leave the studio for a while?

If so,  your station deserves the applause from near and far. 

However, if your plan is just to keep the automation going, you in effect are endangering the whole broadcast industry, giving the public the impression you really do not care about them. Yes, it might cost some overtime from payroll - and sure, it is possible that your station may lose some spots during this - and similar - events.

But really, if you think about it, nature is giving you a low-cost means of promoting your services to the market - and differentiates you from the jukeboxes both on the air and on the Internet. Broadcast is there.

Isn't this a good time to remind your listeners that you stand ready to provide what they want and what they need? (Perhaps it is a good time to repeatedly suggest folks make sure their radios have good batteries in them!)

Radio.  Television.  Reliable communication.  No waiting.

That is something in which to take pride.


What do you think?

What to share your thoughts here?  You are welcome - and invited - to do so.


EAS: Don't Just Sit There - Say Something!

I will make this short and get right to the point. The biggest changes in EAS in 15 years is coming this Fall. It is important to stop for a moment and answer the question: Are you happy with EAS as it is?

If so, fine. you are in one of the relatively few places where the local broadcasters and emergency managers are working well together and program directors ensure any important event is quickly put on the air. You need read no further.

On the other hand, if you are in one of the marginally functional (or non-functional) areas where between programmers and emergency managers hate EAS (and broadcasters) and little goes out on most stations except the Required Weekly and Monthly tests (which are generally fired off by automation systems), this is your real chance to tell the FCC exactly what improvements you want.


This week, on July 20th, is the deadline for comments on FCC Docket 04-296. Reply comments, where you can respond to the comments, is set for a a 15-day period ending August 4th.

Can you make a difference?

Most would say the FCC's stated intention to "fast track" this and push it through means the books are "cooked" and nothing said in the comments will count.

On the other hand, if enough people make their voices heard on EAS procedure or content, it is possible the FCC will hear you.


Do you think EAS usually serves the listener?

When an EAS alert goes off. Do all your listeners know:
         1. There is an emergency? Do you broadcast the alerts in the first place?
         2. Exactly what the emergency or event is?
         3. WHERE it is?  (What about visitors and folks on the highway - do they know your county name?)
         4. What to do, once the alert is over?  (Exactly where to go for more information?)
         5. Who you are/ where you are? (Or is your City of License "hidden" in the middle of a stop set at :47?)

The most common complaint is that the EAS is a "one size fits all" system imposed by bureaucrats who do not understand local needs - and that the FCC spends too much time on fining stations for EAS Violations, compared to fostering a working system that meets the needs of the listener.

For example: with so many stations running the Required Weekly Test via automation, what does it prove? Aside from LPs, few transmissions are even monitored. What does the RWT really accomplish for most stations where the Monthly test works, except as a paperwork exercise for the Enforcement Bureau to sniff at?


With the Third Further Notice of Proposed Rule Making running to 110 pages, there is a lot in there to make your eyes glaze over. The temptation is to just "let it take its course, let the industry group lawyers file those comments."

On the other hand, short, direct comments can have a good chance to rise above the background noise.

Here is a brief summary of the key issues, to give you something to think about.

Common questions are answered here.

Here is where you can make an informal comment. Just fill out the form and make your point.


... If you do not tell the FCC what you think, you will get the EAS system the lawyers want, which may or may not you want - or need. If your goal is to serve your listeners, do not just listen, speak up!

What do you think?

What to share your thoughts here?  You are welcome - and invited - to do so.


A Good Time to Stop and Consider What Regulation is For.

A few years ago, the battle cry was "Deregulation."  In one industry after another, government was supposed to be "backing off" and not tying up businesses in ex-forests of paperwork. Broadcasters were supposed to benefit as well.

As you know, this is the year for the Great Part 11 Rewrite. We have commented several times on the issues and problems involved with the EAS many times. But that is not the only review of procedures going on. Among the myriad other things going on at The Portals, with relatively little fanfare, the FCC last year initiated a review of the Public File Rules, driven by The Paperwork Reduction Act (PRA). In among 20 pages of FCC Rules and Policies under review, DA 10-1741 lists the Public File requirements, 73.3526 and 73.3537 as items for review (OMB 3060-0214).

Last week NASBA (The National Association of State Broadcasters Associations) filed comments with the FCC, pointedly suggesting that enforcement of the Public File rules - aside from the political time part - should be suspended until the Commission can review them and decide if they are really in the Public Interest, or are merely a flimsy device for revenue enhancement.

We applaud this request and hope the FCC will take its role as a regulatory agency seriously, and not operate merely as a "tax collector" a la the Tax Collector in the movie Popeye.

For all the bellyaching we hear from broadcasters that the Public File is rarely, if ever, visited by anyone but station employees, not many filings were made on this matter.

On the other hand, we dare you to find this on your own. It is not easy. Searching the FCC site reveals little. Even if you learn about the RM number (11332), which goes back to 2006, it does not come up on the FCC site search.

After a while, we found this page. It appears that the ploy worked. Three filings are shown on the FCC ECFS page in the past five years, and the comment period apparently closed on June 17th. The page mentioned earlier in this paragraph still shows the proceeding is "open," but that appears to be in error.  According to one DC attorney, the next step is the final comment period at the Federal Office of Management and Budget, after the FCC tells them what it plans. 


Somehow it seems like the goals of the PRA, which directs government agencies to reduce wherever possible the paperwork burdens imposed upon businesses, were never really applied to broadcast regulation.

A look at the comment filed by NASBA shows why it is time for the FCC to change Policy in this area.

  • Although the Public File rules have been in place for 45 years, and the categories and depth of information required to be put in the file have increased, most stations have never seen a member of the Public come and request to see the Public Files.
  • Although many items in the Public File are now available on the FCC's website, the Enforcement Bureau (EB) inspections continue to put a huge focus on finding one or two papers out of order - and generating substantial fines, often several times as large as fines for more serious matters. The FCC EB's page indicates that over $2 million in fines have been issued over the past decade - mostly for missing documents in which the Public appears to have little or no interest.
  • A requirement that certain "related" documents be on file in the Cumulus purchase of Citadel Broadcasting appears to mean that thousands of pages of copies need to be in every station file - over 357,000 pages of copies around the company just to cover about half the applications!
  • The FCC has been collecting application fling fees on broadcast applications in direct contradiction of Section 1.2107(c) its own Rules from 1994 until it quietly changed the Rule yesterday.

If the FCC cannot understand and control their own Rules, can it be reasonable to send out the EB to assess fines to broadcasters who find it hard to do exactly as the FCC thinks it is saying?

Actually it is just plain unreasonable, especially with the FCC itself having most of the above mentioned files on-line, to kill thousands of trees such paperwork - a forest itself for the  Cumulus/Citadel deal.

We hope the FCC takes note of the NASBA comment and request, and moves to make whatever paperwork requirements are necessary clear, easy to comply with, and carry a fine in line with the severity of the issue.

We hope the FCC does this soon.

In the long run, we also hope that broadcasters will keep an eye out and actually comment to the OMB. Let us hope the OMB will be a bit more open than the FCC itself!

What do you think?

What to share your thoughts here?  You are welcome - and invited - to do so.



The Part 11 Re-write - The Good, The Bad, The Ugly

The FCC released the text of the Third Further Notice of Proposed Rulemaking on Docket 04-296 on May 26th - the Part 11 re-write of EAS Rules. This has been long awaited. It could be good. It could be bad. Unless we all make the effort to let the FCC know how we feel it certainly will it certainly will be ugly.

We encourage you to be part of the process. Please let the FCC know what you think. Filing informal comments via the Internet is relatively easy: step by step instructions are found here.

Without going through each and every item (a fuller summary is here), here are some of the key thoughts that you should keep in mind when considering the FNPRM - all 100 pages of it.


The FCC has, at the least, recognized there are some major issues with EAS that are long past due, as well as changes to meet the needs of the new equipment being mandated. There are many aspects of EAS that have been unclear since its inception in 1997, and there is some reason to hope that many will be resolved.

For most every station, the days of strips of hard to read paper will be gone. Aggregating and proving compliance with EAS Rules should become easier.

This is your chance to give comments. Not only the FCC, but FEMA and other agencies in government and from the industry have been involved in the process. As noted, the process to make your thoughts heard is not hard. You can compose your thoughts off line, fill in a half dozen lines on the on-line form, then cut and paste - and you are done.


Sadly, for a number of reasons, the FNPRM has been unexplainably delayed, causing panic to some - and not helped by some of the mis-information that has circulated to fill the similarly unexplainable lack of timely communication from a Federal agency with "Communications" in its name.

Another bad aspect is the announcement by the FCC that they want to "fast track" this proceeding. There is no question that it is far past the time to get this done, trying to rush it through now, just to save a few weeks - and presumably support the September 30th deadline for receiver installation - does not make sense, unless the goal is to ask for comments but effectively ignore them.

We hope wiser heads will prevail and not only approach this re-write in a way that shows sensitivity to users' needs, but clearly announce a reasonable schedule - as soon as possible - that both manufacturers and stations can adopt in their design, production, budget, purchase, and installation cycles. 

Although there is a question as to whether another delay is needed, the FCC seems to have a bureaucratic need to push the September 30th deadline for installation of new gear by stations whether or not there is a system to feed the boxes. Furthermore, there are operation issues - aside from purchasing products - that appear to be brushed aside in the race to make up for all the delays this far. (On the plus side, the FNPRM actually does call for Comments on an extension, so the door to a further postponement has not been slammed shut so far.)

Among the operation issues that seem to elude clear thinking in Washington are:

  • a mandate that all station have continuous wideband Internet to poll/receive FEMA warnings.
  • a lack of clarity and/or plan for integrating state and local information with national materials.
  • how the Governor Must Carry will impact stations
  • and - perhaps most importantly - while all these new Rules will be mandated for broadcasters, the message to emergency managers is merely "please cooperate." Broadcasters who have suffered through 14 years of missed, poor audio on tests and alerts (when the EMs choose to cooperate), and even continuing false alerts naturally are apprehensive of a system that is capable of taking over a station's programming without any consideration to its effect on the programming itself. There are few better examples that one in Chicago, not long ago, where the station was giving clear information and specific direction during a local emergency, when the EAS alert interrupted them to give a generic warning.


Without making any lawyer jokes, why did this FNPRM have to be 110 pages, with something like 315 separate questions proposed by the writers? Yes, there was a great need for overhauling the EAS. But a lot of this could have been done incrementally over the past two or three years, and left the key issues for discussion at this point.

Does anyone think the average station owner, general manager, or program director will actually read the entire FNPRM? Probably only the same federal employees who believe all stations now have wideband Internet available 24/7.

The Governor Must Carry (GMC) has potential to be a real benefit in emergencies, but it also has the tremendous potential to become "yet another interruption" to station operations by people who have no real feel for how to get information to the public unless it is politically useful to themselves.  Already some areas have "Blue Alerts" "Silver Alerts" ... and what other new alerts will be thought of to appease some local advocate?

Finally, we need to emphasize that while large market stations most always already have plenty of Internet access available, many stations still are on dial-up, satellite (read expensive) service, or plain old FAX input. The associated costs are not huge, especially for the larger stations, but for the struggling small town stations the question needs to be asked: is it reasonable to require they buy 24/7 wideband Internet connections?

It is reported that some states actually have provided EAS boxes and Internet connections for their stations. Maybe if the federal government would stop sending money willy-nilly to local Sheriff's and EMs that go for toys, it could supply EAS boxes and Internet service to all the stations.

Then, perhaps, stations would feel a little bit better about the potential of having their programming interrupted without notice or control.

What do you think? Again .. it is important that you let the FCC know. Please do - right here.

What to share your thoughts here?  You are welcome - and invited - to do so.


A short thought on Spectrum

Right now, there is a strange sort of "push and shove" at the FCC about spectrum. It is largely TV related, but radio folks need to pay attention, too. The demand for spectrum is endless.

Supposedly, AT&T bought T-Mobile because they otherwise would not have enough spectrum to build out their system. Reaction ranges from FCC Commissioners who want to see TV stations "voluntarily" give up spectrum and get a piece of the auction price to the NAB studies showing there is plenty of spectrum - even hoarding going on - and there is no need to race to break down broadcast channels. (Indeed, most of the AM, even FM frequencies are of much less interest to the wireless companies.)

This past week some Congressional pushback was raised, primarily in terms of seeking an inventory of frequencies before taking any action. On the other hand, a former FCC counsel has made comments to the effect that public ownership of the airwaves is a passe` notion. In fact, with the FCC Auction concept over the past decade or so it might be argued that companies that buy CPs at the auction need not seek license renewal because they bought the channel. We are not aware of any such court cases as yet, but there clearly could be some issue of two classes of licensees: those that got their CP/license by application and those that bought them through the auctions.

In either event, if you have ever looked at a chart of frequencies and their use, it is amazing how much is in government hands, much like the land in the West (states like Arizona and Utah are overwhelmingly filled with Federal lands unavailable for development). But, as companies like AT&T are using the current spectrum issues to move to a per megabyte pricing model - as opposed to unlimited data - whether there is a real spectrum issue or whether wireless companies are stockpiling frequencies while not really building out their existing systems (have you ever noticed areas where cell sites are situated as far apart as possible? - you find this out largely by dropped calls... ) because, perhaps, of construction costs.

Like the so-called "Performance Royalty" tax ... what happens to spectrum, especially from the "spectrum manager" - which is why the FCC was created - should be something broadcasters need to note and keep an eye on - not merely assuming the NAB has their backs. The "coordination" mess that happened on the 950 MHz band did not impact broadcasters as it might have only because in most places there was no room to add more transmitters whether stations paid for PCN or not.

What do you think?  Let us know.


Site Security - It Cannot Be Left to Chance

The article by Kevin Kidd this week highlights a growing problem - theft and vandalism.

With copper prices well north of $4 per pound, and "used" copper well over $3 per pound, AM transmitter sites (as well as AC units, etc at any site) are attracting attention from the worst parts of society - the drug addicts and other creeps. The thieves are getting bolder and bolder.  Some actually "check out" a site, then spray paint cameras, or just come at night. Others get even bolder, and come out with a shovel and a barrel and see what they can get away with.

Unfortunately, many transmission sites are so far out of town, or in a difficult area, that thieves often can get away with the theft before anyone - station personnel or police - can respond. The fact that scrap yards will all to often take what they get with minimal checking just makes it worse. Can you imagine? During January a couple of yahoos stolen an entire transmitter in Ohio and took it to a scrap yard. If the police had not shown up, the transmitter likely would be shards of metal by now.

So how can stations protect themselves? Money. Kevin kids (pun intended) by suggesting that stations tape $100 bills to the fence, with a sign "Please take this and leave us alone" ... or some such line. The real answer is making station security a line item and put up fences, motion detectors, and video. Even then, unless there is prompt response,  it will be nearly impossible to stop the damage. And the toll adds up fast. A couple of hundred dollars of scrap can virtually destroy an entire ground system. Replacement can be very expensive these days.

It is unrealistic to expect the station engineer to provide security. The bad guys already know that some sites go unvisited for months. They take their time and grab up the copper. Others are more aggressive. Have you seen the video of the two that broke into KSL's transmitter site and stole something like $30,000 in value of copper and tools?

As Kidd notes, fortunately, most of the bad guys are pretty low in IQ, and lazy. It does not take too much to make it too hard for them ... and they move on.

Over the coming months, we plan to share some ideas on how to make your site more secure - and what to do if you are attacked. Short of opening a donut shop (with free goods to cops) or stationing a paramilitary brigade on site, there is no 100% sure way of preventing losses.  But a few simple steps will put you ahead of the game and reduce not only the costs, but the lost downtime - if someone decides to take your transmitter to the local scrap yard.

Your ideas and questions are welcome. What works for you? What can we do to help other stations get the message?

What do you think?



The FCC Fine Gun has been Reloaded -
But is it Pointed in the Right Direction?

The FCC Enforcement Bureau (EB) has always been a bit of a perplexing factor in the operation of stations. Communication is always difficult with these people, their decisions often cause substantial legal expense (in addition to any fines levied), they sometimes take years to even announce a violation, and the rationale can be as obscure as the legal definition of "willful" (no, it does not mean what you think it means, unless you are a lawyer!).

When you add to the trend in recent years to focus on tower lights and fences, EAS logs and Public Files, it is easy to think of the FCC less as an agency to help broadcasters do their best than a revenue enhancement source for the bottomless pit of federal debt. Many remember the days when the Field Inspectors would stop and help a station recalibrate meters, have a cup of coffee, and move on. There was less attention to quotas, fines, etc, than in improving broadcasting as a whole.

In recent weeks and months, the FCC EB has been issuing Notices of Apparent Liability (NALs) like hotcakes.

The question is: what is the goal of current FCC actions?


We would not begin to suggest that all the fines are undeserved. There are many stations that have cut the technical budget beyond reason and either hide behind the promised three year ABIP "vacation" from inspections or simply hope the inspectors will never show. In general, They deserve what they get.  

What else could you really say about a station that did not check the lights on their tower - a clear potential public hazard - except during the daytime?  Or the one that did have an EAS receiver for five years - or another where they disconnected the power cord "sometime between 2000 and 2006 and remained inoperable since then?"  Or the company that is so concerned with ratings and sales that they apparently consider fines for broadcasting prank phone calls a cost of doing business?

There are many basic Rules that get violated because stations start to think "why not, we'll save a lot of money" by not having the Main Studio staffed during business hours, take the time to actually think about and produce the Quarterly Issues and Programs list, or

Then there are the stupid violations, like not giving a proper station ID at the top of the hour or when returning to air after a transmitter or power failure, now lowering power at sundown, failing to repaint a severely faded tower, or demanding the public make an appointment to view the Public File.

We could go on ... and on.

Yet we also hear of NAL findings because a station failed to run an EAS test perfectly. Or a fine issued for some minor matter that happened six or eight years ago. Do not even mention the license renewal debacle during the last cycle, when the renewal application asked if the station had violated any Rules during the last term. Many of those stations admitting such were rewarded for their honesty - with fines.


Perhaps the most annoying part is that there is no clear policy from the FCC to stations on many aspects of daily operation. Sure, there are Policy pronouncements that have appeared in proceedings over the years. But to find the citations and answers tends to require hours of billable time by the DC attorneys. Is this right? Fair?

Many good operators truly do their best to operate by the Rules and serve their community. Still, they cannot help but notice the egregious conduct undertaken by some of their competitors - blatant violation of common Rules - yet EB inspectors seem prefer to ding stations for small paperwork errors.

As an example, there are a number of aspects of the EAS Rules that are unclear at best. Instead of answering simple questions, the FCC has essentially decided to keep all the lawyers busy. How hard could it be to tell broadcasters what day the EAS week starts, or how the "random" requirement for EAS tests - or indeed the Required Weekly Tests (RWT) - do anything except provide opportunity for EB people to assess fines? Perhaps some of these issues will be resolved in the Part 11 rewrite everyone is waiting to see issued as an Notice of Proposed Rule Making (NPRM).

Put more plainly: If a station does or does not issue an RWT, what is the point? Most today are initiated by automation systems, and since no one monitors much beyond the LP-1 and LP-2 stations - and consumer radios do not decode the duck farts - what good does it do? One station engineer forgot to reconnect the audio after repairing a receiver, and it was at least three months before anyone noticed: "didn't we used to have some tones on the air?" someone asked. Issuing fines because RWTs were missed or the Chief Operator did not sign off the logs fast enough does not help the industry do its job.


On the other hand, a good case could be made that some of these fine now being issued are long past due, that stations which have become lax over the years should be paying attention, that big companies who think certain fines (prank phone calls, overmodulation, hiding IDs in a stop set at :47), etc, should pay more and more - till it truly hurts the executive suite suits whose huge bonuses depend upon reducing expenses above all else.

Possibly it might even be time for the Commission to strip a license or two for egregious actions.

One can only contemplate the litigation that would ensue, but when KIKX Tucson lost its license in the 1970s, for a prank on the air that went bad, why should not a company that thinks pranks are a cost of doing business lose a license or two?

We continually hear of stations operating for years with no license or regularly failing to reduce power at sundown - not to mention the pirate issue in many areas. There was even a high powered station that did not change the Directional Antenna as required (one source said they could not!). Another, in a major market, was said to have operated without changing power/pattern for years.

Some broadcasters have tried to point the FCC to the real problems by filing documents showing the illegal operation, and are routinely ignored ... not even receiving an acknowledgement of their efforts to document the problem. In some cases, the EB arrogance has reached the point of suggesting that interested parties "watch the FCC site to find out what happened" ... even though it might be years before the EB actually posts anything, if at all.

With huge corporate ownership and management bureaucracies often overruling the engineer, placing blame is a bit more obscure, but as we all know, ultimately it is with the licensee, even if it is more of a fiction than fact that the licensee actually knows what is going on at all the stations owned. And this is where lawyers rush in, fingers are pointed at "that *(&^# engineer we fired last month," and the "NAL dance" is performed.

It is for these reasons that bigger fines are justified in many cases - but not all. There sure is no indication that there any motion to actually fine the managers and other people that purposely ignore the Rules.


One big issue is whether the current cluster of enforcement actions and fines will change the way stations operate. If they do for the better, that is good. If we see a lot of "marginal" enforcement actions, it will not be good - it will further deteriorate the relationship the broadcast community has with the FCC. One has to wonder what the goal of the EB really is in this matter.

"Back in the day" most engineers - and even combo jocks - had respect for the FCC and the Rules. None wanted to be fined. They protected their licenses by knowing and obeying the Rules and Regulations. Very few had their licenses pulled.

Today, knowledge of and respect for the Rules is often replaced by ... well ... is often not replaced. Too many stations just operate as they do until something happens. While it may work for a while, it really is not good business.

To help identify and lead folks to information about what the EB is looking at, and what the potential costs are, we have set up a page of resources:

There you will find links to the FCC "Self-Inspection Checklist,"  some advice on how to avoid fines, and the newest feature "Enforcement Watch," with information on recent NALs, and links to the Rules involved.

We hope this will be of help to you as you seek to keep your stations operating in accord with your Authorizations - and free of fines from the EB!


A New Year ... A New Start

As broadcasters, we have been bruised like the rest of the economy. In some cases, worse, because so much of the industry has been automated.

However, as with many things in life, it is important to control what you can. On the tech side if means we are generally perceived as a service department. So, if we can super-serve our customers, we make ourselves more valuable in the eyes of the rest of the staff. That is good. And a good way to start the new year.

What is not so good is that finding new jobs these days often requires leaving an area, with the concomitant problems of tearing family away from jobs, schools, and friends. In many markets where there were 18-20 employers, some with multiple engineers, now we often see three or four mega-clusters. That also makes networking at SBE meetings harder, with fewer local techs and jobs to go around.

So, is 2011 the year things will turn around? That remains to be seen. It is clear that the industry will not be returning to the model we saw in the 1980s and 1990s. And, unless and until station owners see the need to build more content for the listeners and/or viewers, the attrition to portable devices is likely to continue. After all, even many broadcasters listen to the commercial-free online streams; given the chance, none of us wants to listen to 10 spots in a row.

Nevertheless, as we see the new products at the consumer shows like CES, we can tell what changes are coming ... and have a clue as to the technologies needed. Perhaps we are going to be much more IT oriented than RF, with more and more self-diagnostics being built into transmitters. But the bottom line is that the technology used is not so simple that stations can eliminate the tech departments.


So, we are back to customer service. Each of us needs to consider what are our strengths and weaknesses - and act to shore up our knowledge in the areas we need to better grasp. During times of reduced station budgets, this means that it is just as important to maintain service credibility and availability by not taking on too many stations as it is to take the initiative to reach out for the education. And that is a great challenge.

Bottom line: Whether or not we are fans of HD, FMeXtra, or other tech, we need to be able to install and maintain the gear when called upon to do so. That requires we spend some time learning about things we do not normally use or maintain. When an employer adds some new tech to the facility, it now becomes the right time to learn about it - not when it breaks down!

The problem is that with larger clusters and fewer engineers, finding mentors is harder than ever. Many manufacturers are putting out tutorials, even web seminars. But this is only a partial solution - without good hands-on training, it is hard to truly learn the craft. That is not to say that alternatives are no good. It is easy to say that education is necessary, but the key is to do it correctly, not inexpensively. If a company tries to rely on web seminars, they are doing only half the job.

Individually, we need to be proactive, making sure we keep up with the current state-of-the-art. Then we are going to have happy "customers" ... the stations where we work or at those where we are contracted.


Many news reports discuss people out of work for two years - or more. That puts a lot of pressure to take whatever jobs are open. This is a time to be clear about what it means to be a broadcast engineer. True, each person alone must make the decision to work for what wages are offered. Furthermore, the "new normal" may not be same as before. 

The trouble comes when a station tries to hire fulltime or part-time contractors at below normal rates, and then pack on additional duties, including installing and maintaining transmitters or automation systems - or dare we suggest, plumbing duties - for example. An engineer is worth a decent salary (or a proper charge by contractors) when they are hired. If it is for 24/7 coverage, a proper amount of money ought to be there. Even if you need the job, it will pay off not to give in too easily to a low-ball offer. In the end you will get the respect you deserve.

Be careful - especially be resolved that you should not use your money to buy things for a client. It is not unheard of, for example, for an engineer to be laid off just after the installation is complete. Nor is it uncommon for the contractor to suddenly find himself responsible 24/7 for an automation system, without even being sponsored to the training program. They count on the engineer to learn the system on their own time and provide support. It is a very short-sighted policy for stations to do this, but it does happen.

If you are required to learn a system, go ahead and do so. But make sure the facility pays for your time.


Broadcast engineering is a business. The only one who can make sure it is a profitable - and satisfying - business is you, yourself.

What do you think?  Please do let me know.


Serving the Public Interest, Convenience & Necessity

The major loss of telephone and Internet communication in the Reno, NV area earlier this week should give pause to those who continue to marginalize the part broadcasting plays in local communities. Yes, times have changed. Yes, there are more choices for consumers to get their entertainment and information. At least that is true until something happens.


It used to be that every broadcaster knew what PICN meant: the Public Interest, Convenience, and Necessity. It meant that when the community needed to know something, the broadcasters were on it. Live and Local. People turned on their radios (and televisions) to find out.

Perhaps it was to find out whether or not Johnny's school was closed due to snow or where to go to help neighbors deal with local emergencies. Perhaps it was nothing more than finding out if the local High School made it to the playoffs. Broadcasters were there. Not endless tapes of oldies and commercials played from an unoccupied building.

True - times have changed. The sheer economics of broadcasting have forced some changes in how stations operate. The FCC auctions have led some to feel "I bought my license - I don't have to do as much Public Service as others." And even though most markets have automated stations that never change - even if a tornado blows through - unless they are knocked off the air, many broadcasters do remember the PICN and, when thing happen, they get on the air quickly and deliver for their listeners. 


The Emergency Alert System and its predecessors have been put into place by the FCC and broadcasters to share information and get it out as quickly as possible. In many places it works well. Lives have been saved.

In Nevada, a backhoe fade (when a contractor cuts through a major trunk line or fiber optic cable) caused the whole 911 and cell system to go down. There was no Internet to "google the news" or "tweet" that you needed help - or anything. There was no reverse 911 for some county manager to use.

On the other hand, EAS will work when backhoe fade happens.

In Nevada, there were broadcasters who stepped up and got the word out. And as the news of the problem circulated, aided by the EAS messages going from station to station, we can only assume a lot of public panic and anxiety was averted.

Of course, this does not work everywhere. Large metropolitan areas and those along state lines are among those places where EAS has often failed to shine. This give those who ridicule EAS an opportunity to point to such failures. But as we just saw in Nevada, it EAS can succeed.

Situations such as in Nevada show why it is imperative that local stations prepare and be ready to help deliver information tailored to the community. Getting that on the air is the responsibility of broadcasters. Saying that everyone went home for the night or the weekend and there was no one on duty is not good enough. And, in these days of multi-sourced entertainment and information, it is almost suicidal for a broadcaster to miss a chance to shine in the community by "super-serving" it.


In many stations EAS issues are left to the engineer to handle. Mostly tests and logging. But the engineer cannot require the news department (or news man, as the case may be) to rush over and take over the airwaves. In one case, as fire raced up a mountain, cutting the power lines, and then headed down the backside to a small community, the engineer for their only local station was instructed to set up an emergency transmitter - in the large city nearby, so the oldies and commercials could run.

The residents of the small community had no local voice at all - they could not even hear "their" station. But the commercials did all get on the air. A curious rendering of PICN.

Meanwhile. stations that have a plan can respond to emergency situations and shine. They show why they are valuable members of the community and deserve support from the residents.


There is much chatter in the trades about whether broadcasting as we have known it will cease - perhaps aided by an FCC and Congress that wants to sell off frequencies for cash.

The industry, as a whole, needs to step up and show that it is not merely going through the motions at renewal time but desires to be an asset to their communities.

Those Nevada stations that became the information center this past week deserve commendation. Those that did not? Well, one can only wonder what their listeners think ... if indeed they are still listeners.

(What do you think?  Let us know at the "contact" link)


Why Someone Has to Listen

Responses: Tom Ray                 
John Stortz            

In the past three months, a serious situation has developed that needs more attention in the field.

PLEASE - make sure someone is listening to your air product. It could save you a lot of money! In these days of automated clusters of stations, do not treat this as of little importance. Just because you have a modulated signal it does not follow that you are legal - even if you are running a satellite network program.

Here is why: for the second time in three months, an advertising agency has thought that running EAS data bursts in a commercial was a great way to get attention to their spot. The only trouble with that is it devalues the effect of the EAS sounds during actual emergencies, it is illegal, and can result in fines to the station running the spot.

Please do not stop reading. Yes, EAS has become a sad joke to many in the industry and among many in the general public. But, this is not an EAS-oriented editorial, even hough the symptom appears to be EAS data bursts.

The following is very important because the FCC Rules we are about to share with you do not affect the little geniuses at the ad agencies, the producers of the spots, any network that carried the spots, nor the salesmen who sold the time. However, if the Enforcement Bureau (EB) receives and investigates a complaint that your station caused alarm to local listeners, it is the station itself that is liable for what could be a nasty fine, especially if repeated airing of the commercials is proven.

Reports indicate that it has been the engineering community that has stopped or prevented the airing of some of these spots. That is good, but it demonstrates several problems in the way many stations operate today.


The FCC Rule that applies is Section 11.45, which reads:

11.45 - Prohibition of false or deceptive EAS transmissions.

No person may transmit or cause to transmit the EAS codes or Attention Signal, or a recording or simulation thereof, in any circumstance other than in an actual National, State or Local Area emergency or authorized test of the EAS. Broadcast station licensees should also refer to 73.1217 of this chapter.

Section 73.1217 is entitled Broadcast Hoaxes and relates to broadcasting false information that could be foreseen to cause "substantial public harm" and actually does. For example, think of a joke about a chemical spill or bomb threat and how people could get hurt in a panic. Or a warning sound that causes a car accident.


As noted, the Rule is placed upon broadcast and cable facilities, not the ad agencies, etc. It states pretty directly that sending an EAS signal "... or a recording or simulation thereof ... "  is a Violation. Under "willful and repeated" - which the EB lawyers can interpret as even one airing - all it takes is a complaint from the public. And, do we have to remind everyone that even if the complaint is eventually dismissed, the legal costs to defend a station can easily exceed the fine?

Here is what you need to know: In September, a run of commercials in some Western states for ARCO/BP included the data bursts that opened up some EAS receivers. The EOM data burst appeared to be from a Tampa station.

This past week, advertising for the new movie Skyline on television and cable included six sets of data bursts indicated an RMT in Pennsylvania.

In both cases, the spots were pulled after the technical folks heard the spots and alerted the industry. Unfortunately, many of those on the sales and programming side have never read the Rules or apparently are too young to remember "The Singing EBS Test" and the written frown issued by the FCC at the time.

Hence, in the past week or so, reports from around the country include several false RWT's issued as a joke during a program on the Fox Sports Radio Network that apparently decoded to Athens, OH.  There was also a program on the cable network TBS where a comedian decided to use EAS data bursts and a screen crawl to make snide comments about the "bit."

All of these are clearly illegal under Section 11.45 - and most of the originators were not under FCC control. You might be.


It does not matter whether or not an actual EAS message that was transmitted. The Rule says "a recording or simulation thereof ... " is enough to trigger a Violation, leading to a fine.

And under current thinking in DC, even one time is enough to start an investigation. Think about how one complaint caused huge problems for KWVE, for example.

While it is true that under deregulation and consolidation, many stations and clusters are running with fewer and fewer personnel and more and more satellite programming. This does not relieve the licensee of the responsibility to monitor what goes on the air - and prevent the sort of abuses described above.

Unfortunately, listeners continue to hear stations throwing dead air for hours on end when the automation fails or an audio processor freezes. One can certainly assume that station personnel are unaware of much of what is broadcast - until a complaint happens.

PLEASE!  Ensure that someone from programming and/or sales is assigned to always monitor your air product. While it is never easy to predict what the EB will do - or when - the number of these violations is increasing. Until the industry teaches the ad agencies, sales departments, and production personnel about the Rule, this will continue until the Notices of Violation start to spread.

With increased attention to EAS because of the forced purchase of CAP boxes by stations - most of which will never need or use CAP as it is now set up - and the coming re-write of Part 11, it only seems prudent to pay attention to this and the other content Rules that broadcasters must obey.

You could save a lot of money and aggravation by training your key personnel to be vigilant on incoming programming and commercial content. Sit them down. Explain the "Singing EBS Test" to them. Help them see why broadcasting things like EAS data bursts is not "something funny to do."

The FCC sees no reason to issue any memo, warning, or Declarative Ruling on the subject, because the matter is pretty directly settled in Section 11.45   However, it seems to us there still could be ambiguity with the use of sirens, horns, etc.

And while you are at it, compliment your engineer if he was quick to alert you to this problem. At first you might have been a bit annoyed; you might have lost a sale - or had to do some make-goods. But his report may have prevented much more costly problems as well as the devaluation of what could be a valuable source of information and public safety instruction in time of disaster.

At least he was listening!

(What do you think?  Let us know at the "contact" link)

TOM RAY Responds:
You are spot on.  No one is listening. 

Technology is a wonderful thing.  It saves us time.  But have we gotten to the point where we simply drop things into the automation system without checking them?  That is VERY scary.  What if the wrong file were sent and you got the outtake (remember the TV Chesterfield Queens spot that wasn?t supposed to air and aired on network TV?  I suppose you have also heard the Rod Serling NY Telephone spot?).  In this case, we got an EAS test. 
Second: even scarier - I don't think most outside of the Engineering department would be able to identify something that sounds like EAS tones.  So while someone may listen to what is in the automation system, they may not comprehend that something is wrong. 
Third: have we gotten this low that - when something is identified as being illegal - we have to argue with management to get it pulled?  Do we all really need the money that badly that it's full speed ahead and damn the torpedos? It's illegal, so what??  Let the client be upset that his spot was pulled.  IT'S ILLEGAL!  They should be able to comprehend those two little words, coupled with a copy of 11.45 to back them up.
I think we, as an industry, are sinking to a new low.
om Ray
VP Engineering Buckley Broadcasting
WOR, New York

John Stortz Responds

If I were the GM, I would drop participation in the present EAS plan. Whenever I mention that, someone will gasp & remind me: "BUT, if an alert is activated, we would be required to sign off." Sure. But only if the US President activates EAS. And how often does this happen? Has any President activated national EAS? Not to my knowledge.

We are a regional group of stations, unable to direct a message of local content. And we are not required to do so with State or Local alerts. The way the Florida State Plan is configured, there is no local entry, without the local agency getting a message routed thru the State EOC. The State appears to be unwilling to tackle this & our LP station [singular] has channeled all State alerts to a subcarrier & call it "LP-2." Even our LP-1 station ignores state & local alerts.

If some event becomes so big that is causes the President to activate EAS, Most people will already know about it & be turning on their favorite TV station so they can see as well as hear. So without listeners, the radio station can easily shut down for a few minutes, just as we do in the middle of the night for maintenance..

John Stortz


EAS - Will it Ever Really Be Ready for Prime Time?

Responses: Warren Shultz
Dave Burns

The seemingly unending march toward a better Emergency Alert System

I'll keep this simple and straightforward: while there is no reason to panic, all the poor judgments, the parochial actions, political positioning, and downright lack of attention from large segments of the broadcast industry are about to culminate in some annoying problems for everyone: a "new EAS" that has not really been thought through from end to end.

(Want to see a Question and Answer discussion of key points?  Click here.)

True, there are some signs that a few companies are starting to pay attention, but that is mostly because money is involved.

The essential nature of the EAS is at odds with industry practices, listener expectations, and a mess of government mandates that do not really include the entire body of stakeholders.

At the very end of September the long-awaited announcement by FEMA of their adoption of the CAP V 1.2 finally happened, starting the "180-Day Clock" countdown mandated by the FCC.


The problem is that nothing more than FEMA is ready. The FCC certainly is not ready, aside from the lawyers in the EB who think their whole job is to find technicalities to generate money (think KWVE). In fact, more than a few cynics say the FCC has dragged this thing out so that broadcasters will be in a panic, make mistakes, and be subject to more silly fines for a system many stations do not really want in the first place.

The Part 11 re-write has not seen the light of day - not even a preliminary view. Some of the manufacturers of EAS gear continue to see a need to wait and find out what the Rules will say before committing to the expense of producing the EAS boxes with CAP capabilities. For example:

  • How will the mandatory "Governors' Override" be handled? 

  • Will the useless Required Weekly Tests be abolished?

  • When will we see a reasonable test of the entire system, EAS or EAN?

  • What should stations do if they do not have reliable (or any) Internet access?

This is not to mention the other problems:

  • The IPAWS protocols are not finished - and are not compatible between versions 2 and 3

  • Many companies will find the 180-day clock is impossible to meet given capital acquisition and expenditure cycles

  • Most manufacturers do not even have their final design ready for production.


All the way back to Conelrad, the idea was to make the US broadcast stations available to the President in case of emergency. We have that basic capability - although the Alaskan Test in January identified some problem areas. Unfortunately, they are caught up in the bureaucracy - and there is no current plan at FEMA to tell everyone what went wrong, nor why they are taking a full year to do a follow-up test.

But a major issue is why are stations being required to buy and use CAP devices when there is no state nor local framework anywhere to put them into use? In fact, for the vast majority of non-TV stations, there will likely never be a need for CAP output. In the unlikely event an automated station needs information, it would be simpler and quicker to have a web address and look for it. Or call for a FAX from the local Sheriff's office.

While examining the problems, and possible solutions, it becomes clear that among the large stumbling blocks are the conflicting goals of different governmental agencies with different foci - and none seem to have either the authority or the will to put into place a framework that covers all the important players.

  • The FCC cannot force the emergency managers (EMs) to cooperate with the broadcasters, and in many places they refuse to do so.

  • FEMA might be able to do so, but thus far have limited their actions to the national EAN distribution model.

Do not misread me: there are many sincere, hard working government folks trying to make things work. They should be applauded. But there apparently is also a lot of bureaucratic infighting and turf protection, resulting in Rules that affect one side of the distribution chain - threatening fines - while the other half is just "asked" to cooperate.  A recipe for disaster, as has been seen many times in recent years. Do I have to say "reverse 911" to explain?

Of much more value would be Rules requiring someone to be available 24/7 to receive - and act on - emergency information, whether by Internet, FAX, email, or some other means. Of course, that would require a national law to force emergency managers to communicate with the broadcast media. So, this is a broken link likely to remain so.

Another major broken link is at the output of the system. Listeners want to know three things - and quickly:

  • Exactly what the emergency is and where it is happening.

  • Who, What, Where and When with the station call letters must be in any alert. (And not from an ID hidden in a stop set at :47)

  • Where it is in relation to where they are (and not with some arcane county name)

The current system often fails to provide any of these three critical pieces of information. Yet, there is NO indication that FEMA or the FCC really seem to understand this. The emphasis at FEMA (and, to be brutally honest, rightly so) is merely on getting Presidential access to broadcast facilities. But a technologically solid system for that is essentially in place already. The people who have been working hard for the past several years on CAP, IPAWS, CSRIC, etc, have done a good job of getting the message out to broadcasters. Sadly, the main result is anxiety and panic about buying equipment that is not fully ready.

Finally, there is the connection between the listeners and the broken linked EAS - the program directors and station managers. In far too many cases, they do not want any of the EAS alerts on the air at all, with the exception of those mandated. That means EAN, RWT and RMT. Period.  Once they find out the Governor (or his designee) can appear on their stations, open-ended, at will, they will be upset. But it might be too late at that point to make any common sense changes.

Frankly there is still a lot to be done to make the EAS useful in many places. We can only hope the NAB will do more than just try to delay the expense of buying the CAP machines, and address the underlying problems in a way that will provide a robust, useful emergency alert system without mandates that are little more than traps for the collection of fines.

In some places the EAS works and works well. Sadly, state and local politics, favoritism, and downright incompetence have made the EAS a joke in far too many places.

Is ANYONE listening in Washington?



 The entire CAP product is an IT-developed alerting system and should not have been forced on broadcasters at this point in time. It is a political solution that does not work for broadcasters.  

This all goes back to a very weak FCC knowledge base and having no EAS Czar to oversee the product. Because of this, EAS is a headless snake weaving its way through the federal bureaucracy. At last report the EAS concept spans nine federal agencies with no one at the head. We are nine years out from 9-11, yet we have failed to improve the warning system in place as revised in 1997. 

FEMA has given so much traction to this faulty product simply because the IT side got their attention. 


I suspect in the testing this will be found out. FEMA has only approved the software. The FCC staff of attorneys has no idea what to do with the CAP product and was not consulted on the development of the product. Like the rest of the broadcasters all they heard was the media hype.

What we know:

  •  The CAP payload is so large it cannot be handed off over the defined wireless broadcast relay network commonly called the “Daisy Chain.”

  • Stations are expected to have and use reliable Internet connections to access CAP data.

  • CAP does not meet the Presidential EAN requirement for a live audio feed.


Of course, there are tools already in place: the legacy EAS system. The defined EAS network is a wireless concept that depends on wireless broadcast stations to hand off an alert over a defined path.  

History has shown (during past emergency events) that the broadcast plants are a survivable link not dependent on landline or Internet to function. Indeed, why are NAB and others pushing to activate FM receivers in personal wireless devices? Because when all else stops that is all that will be working. 

Of course, these tools have not yet been tested or fully utilized. 

·         FEMA is going back to the State of Alaska for yet another EAN test this January, 2011.

·         The FCC has proposed an end-to-end test of the EAN hot code nationwide. But this nationwide test has yet to progress and has been pushed back a full year into 4Q 2011.


Instead of adding the CAP overhead to all EAS transmissions, I am calling for a plan in which NASBA (the National Association of State Broadcast Associations) leads the nation to draft and submit a letter to halt the CAP insanity – instead requesting the FCC to set a reasonable three-year rollout plan for CAP compliant equipment. 

In the meantime:

·         Testing - CAP compliant testing should be done by independent agencies and not the manu-facturers or developers. 

1.      Testing should include compliance with Presidential Directives for alerting the America Public.

2.      A year should be allowed for through testing in the lab and field, so we do not end up with what we have today - an untested Alert system. 

Note: FEMA has two test labs. One is a Kentucky university operating under a FEMA grant for EAS equipment testing and the other is JITIC (Joint Interoperability Test Command) lab on a military base in the Washington DC area. JITIC tested the DEAS (digital alert system over the PBS HDTV satellite backbone) and rejected the future development of the product.  DEAS is a dead end product. 

·         Rollout - A two-year rollout should be started for the change out of the existing equipment this will allow time for stations and alert centers to budget and replace their aged legacy system equipment.

It is, after all, pointless to install a relay base of CAP equipment when the sending portion has not been deployed.

If the government bureaucrats will just take a step back from their empire-building, we could stop this train wreck and, instead, build a system that will be of use to stations and the emergency management communities.

CAP is not ready for use in the real world, no matter what FEMA says. Someone needs to stand up and say so. I, for one, am doing so.

Warren Shulz
Former Chairman Illinois State EAS Committee


The ongoing buzz about the released Common Alerting Protocol (CAP) and its use with the Emergency Alert System with the FEMA acceptance of CAP almost totally forgets concern and compassion for the average citizen at the local level.
All of the drive to improve technology to and ensure that state and federal messages get through the nationwide broadcast-radio-daisy-chain in a disaster, appears to forget about us on the home front.
It happened to me and my wife here in Richmond 2 years ago as we absorbed a little of the tailend wrath of hurricane Ike.
Our neighbors in nearby Cincinnati were in an emergency situation for two weeks.  Fortunately we were out of all communication, and more than a little nervous for two days.
We depend on Comcast cable for television, internet and telephone.  Cable was out.  Our cellphones are incapable of text, so there was no alert or warning or helpful information there.  Cell service was out anyway, for those two days.
Historically we have always turned to ubiquitous radio in these situations.  We have 4 battery-operated radio sets.  Our local stations were entertaining, but were on auto pilot/robot operation for that entire weekend.  No local information or warnings on important things such as how and whether we might get to medical care, food, potable water, what roads were closed due to live electrical wires down, trees across roads, etc.
Our situation, in a smaller and thankfully less dangerous way, was not unlike that of  Minot, ND.
On January 21, 2002, A train derailment in Minot spilled harmful chemicals creating a toxic cloud that scared residents and which was responsible for at least one death.
Local law enforcement through emergency management personnel were unable to execute radio EAS (Emergency Alert System) procedures that night because, tragically, local emergency management people had not installed equipment for this purpose. Instead, in the midst of chaos, they turned to telephone lines which were already clogged by calls to them from citizens attempting to learn what was happening. As a result, the local community was not fully and immediately informed of a life-threatening situation.
It was determined later that the Minot EMA authorities did not preempt regular radio programming to get the emergency warning on the empty local radio station.
A train derailed in Graniteville, SC, At 2:39 am on January 6, 2005,
spilling harmful chemicals. This resulted in 9 fatalities, sent 550 to hospitals and 5400 people were eventually evacuated.
Local emergency agencies (EMA) were not successful in manually interrupting radio broadcasts to alert citizens of the dangerous conditions.  Local EMA-type authorities sometimes have the ability to do this.  They should have the ability to do this since 90+% of radio stations are devoid of human population much of the week.
There is a solution which should be included in any arrangement. No, it's not stations' 24 hour staffing. That would kill many operations.
Please consider the positives of stations working with and ceding friendly commandeering of their facility to and by their local EMA, first responders, and law enforcement officials. There is always somebody at EMA and, properly equipped, they can and will interrupt programming for these empty automated stations to help keep their citizens alive and well.
Encourage and empower our radio stations to perform in the public interest, convenience, necessity and safety which has always been a source of pride for them and which they've accomplished historically with pride and dedication.
Station operators' vital and irreplaceable links of information, alerts, and warnings down here on the local level will fulfill an obligation they've always paid with great alacrity to their listeners and to their advertisers.  It's only good business.  No operator I know would want to face their listeners and advertisers after an unreported serious disaster.
For radio broadcast, only, something north of $20 million is about to be spent on new CAP-capable EAS receivers. Cash investments which will result in new equipment for this purpose occupying a rack space or two in the station, complying with the letter of the law, but useless and worthless at the local level without motivation for performance.
Small and medium radio operations, primarily for economic reasons, have been forced into precarious positions regarding the most dependable source for emergency deployments of alerts, information and warnings.
We believe that overtures and exchange of information between and among station operators and EMAs, first responders, fire, police, sheriff, EMTs is imperative to add security to any plan.  Your personnel's contact information, landline and cell, so that, if necessary in the big one, a pickup could be arranged via helecopter or snowcat, etc.  I'm sure stations' operators dedication and commitment could make this happen.
Articulating as clearly as I can, any interruption to a station by others must be a real emergency and that
must be stressed in any arrangement as described here.
Please help local public service.  Save lives.  EMAs can make you heroes with very little or no continuing
If your tower is not on the ground, you can reach us like no other medium.


Dave Burns



Should FM Chips be mandated for Cell Phones?

There has been a lot of "buzz" lately about the efforts on the part of the NAB to promote the addition of FM chips to all cell phones, turning them into FM radios. At first, I was totally against it. However, the more input I get and consider, the more I can see some good possibilities, if the efforts do not get derailed in political fights.

The potential drain on the battery notwithstanding, having an FM radio in every cell phone could be a good idea. Perhaps you have noticed many people today no longer wear watches - but they carry a cell phone everywhere. Having a way to reach out to alert them to emergencies and dangers would be a true public service.


One good argument actually exists: although cell phone companies have the ability to issue "broadcast text alerts" for emergencies, it is a character limited ability - but one they have rarely bothered to implement. Having an FM radio at every cell phone equipped hand during an emergency might be a good idea. Broadcasters are often the only lifeline communities have in times of emergency.

On the other hand, there is still a lot that would need to be resolved before this would truly be a useful solution to a problem. For example, can good is the reception that can be had on a cell phone, aside from the most powerful stations? Where does this leave the smaller stations? How would a useful antenna be implemented (remember the Apple iPhone antenna mess from a couple of months ago?) without requiring users to keep a long wire attached to the cell phone? What about battery life? And, is this to be HD capable (even more battery stressing) or analog? 

And then we have to ask: what about AM stations?  They were promised HD would revitalize the AM band. Most AM operators would suggest that promise has not done much for them. There is nothing here for AM in the current proposal.

Furthermore, some would argue that Radio has boxed itself in, with years of shoehorning marginal facilities onto the AM and FM bands, with little thought to actual Public Service. More than a few stations cannot truly cover their City of License, even if there were staff to provide content.

Unfortunately, part of the NAB's effort is tied to the Performance Royalty Tax issue that has been pressed by the recording industry for the past couple of years. The current NAB leadership appears to be trying to make a "package deal" where the industry would accept a small royalty fee in return for having the government mandate the FM chips in cell phones. To some this seems like a good deal. Here I am not so sure.

The biggest hurdle to overcome seems to be in identifying the basic goal. Is it to get listenership for Radio? If so, the Performance Royalty issue is going to be a big one to overcome. Discussion of that aspect is more oriented toward the owners and managers arena - after all, engineers, programmers, announcers, and other staffers have little to say or do in the face of such payments.


If the big concern and issue really is about getting out information during emergencies, there are several major problems - and these affect more folks than realized by most.

  • First, there is the coverage issue. Well, clearly any coverage is better than none.
  • At the same time, the EAS has proven to be a broken system. Will having FM chips improve a system that is not working very well now?
    • Most stations will not run any EAS alert except those required (including the increasing useless Required Weekly Test) by the FCC.
    • Those that do often give only vague information on the locations involved. The name of some county gives no useful information to people driving on the highways. When drivers can get seven different stations running the same satellite talk program, each hiding their station ID in the middle of a spot set at :49 and identifying only a county (or counties), how can a listener know if they are not driving head on into a tornado, for example?
    • Stations often over-hype any storm or possible danger to the point many listeners no longer pay attention. 24/7 coverage of hurricanes that do not actually cause much damage make it harder for authorities to get cooperation during the next event.
    • Many Emergency Managers who have EAS entry points view it as the last thing on their list to do - there is no partnership with broadcasters in many areas, and they do not welcome scrutiny of their actions and timing of warnings during an emergency. News reports continue to feature EMs who think "reverse 911" is the Holy Grail of warning systems.
    • When alerts come from EMs or the National Weather Service, they often are unintelligible either due to personnel who do not know how to speak into a microphone properly, or have long, rambling text messages written by someone who thinks "legal" not "communicate." The results from a lack of training or priorities, from personnel that do not know nor really care what their message might do to cause listener tune-out. "That's not our job."
    • With LP stations worried that the FCC will issue fines for any slipup, there is a lot less interest in doing anything except relay the required tests and alerts.
    • With so many unattended stations - especially over holiday weekends - there is little opportunity for stations and EMs to communicate at all. Should there not be someone designated at every station for 24/7 contact?
    • While CAP promises more data, more information, who will be in the stations to see it?
  • Meanwhile, the bureaucratic fiddling has not helped. Unfortunately, it is the nature of governmental agencies to study, confer, delay, and communicate only when they unveil new policies and laws after they are adopted - and often without considering how they really will affect those involved on the state and local level.
    • After years of talk, FEMA and the FCC are still debating possible changes to Part 11 and the final standards for implementing new EAS procedures, the CAP, and what new hardware stations might be forced to purchase.
    • Although the first ever EAN test was conducted in Alaska in January, have you heard anything since? Any information at all about what changes need to be made? When the promised National Test will occur?
    • We keep hearing about the "180 Day Clock" when stations must install CAP. The start of the clock keeps slipping. The reason? We are not sure. The agencies that control this are not talking. Once the clock does start, will it be subject to NASA-style "holds?"  And who will pay for the new boxes? All in all, we have a lot of questions.
    • The engineering community has done tremendous work in the recent years to develop a system that could deliver a lot of information and data to stations. But the best system in the world is useless if no one uses it.
    • Management and programmers have yet to be truly brought into understanding what is coming with the new receivers, the mandated "Governor's Override" and what this might mean to their on-air product. Why not?

It may sound a bit like we have drifted from the issue of the FM chip in cell phones to problems with the EAS.

Perhaps we have.

But they are interrelated.

Maybe this is a good time to get NAB, NASBA, owners, and managers to give attention to the larger issue of how stations serve their listeners. Maybe if they sat down and helped form the outlines of the next generation of EAS procedures, the nation and local authorities might have a warning system that was more than an aural "annoyance" (a recent cartoon called EAS the "Extremely Annoying noises System) and more of a reason for people to remember to turn on the radio when there is an emergency or other such event.

If all this talk about adding FM chips to cell phones puts some attention to the EAS from the entire industry, then we have the starting point where options can be explored. If no one pays attention, an unfunded federal mandate will eventually come out of the bureaucratic cubicles that will merely cost stations money, while making little difference in the overall warning system.

Do I want to see FM chips in cell phones?  Yes.  No.  Maybe.  This could be a great idea. It could be a waste of effort. Frankly, I think it all depends upon whether or not everyone makes their voices heard at the FCC, FEMA, and NAB. Yawning could be dangerous for EAS and Radio itself.

What is your opinion?  Use the "Contact" link at the bottom of this page and let us know. 

Submitted Comments: 

Richard Rudman  - - 9/4/10


Your editorial on FM chips in cell phones will hopefully spark some serious thought about the role of broadcasting in warnings and the overall issue of getting emergency information to people at risk when it counts. One thing I hope it sparks is recognition at the NAB that some in the broadcast engineering community believe that this proposal has some merit.
For this proposal to have more merit, here are some of my thoughts:

  • The consumer electronics industry should build EAS/CAP-awareness into not only cell phone chipsets, but chipsets for all personal communications devices. CAP warnings have the potential to carry far more accurate emergency information than can be conveyed by the current EAS system. In my opinion most of the really valuable information that CAP could bring to radio will not carry through because of the legacy EAS "filter" it will initially have to work through.
  • I would venture to say that most FM stations do not have news departments. FM stations need emergency mutual aid agreements for blanket automatic rebroadcast rights with AM and even TV stations that do have news departments. I know of at least one cluster that does this internally - literally able to go "all emergency all the time" on all of their six stations. Their Spanish language stations do a lot of real time translation. The breakthrough will be to create EXTERNAL agreements that instantly kick in when everyone in a community finds themselves crowded into the same leaky boat. Again, we have seen examples of this play out in events as diverse as the Northridge Earthquake, Hurricane Katrina, and recent wild fires in Santa Barbara, CA. Why not plan this in advance so FM radio can call itself a legitimate and valuable real time resource for post-warning emergency information?
  • We need to have dedicated VHF and UHF radio channels to distribute state and local CAP messages direct to as many broadcast stations as possible. CAP messages are not designed for relay that has been done by the current LP distribution model that perpetuates the old "daisy chain" single point failure mode we thought we got rid of the old Emergency Broadcasting System (EBS) and launched the EAS. Washington State stare calls these Local Relay Networks (LRN?s). This is an elegant distribution model we should all follow. Local and state governments should make LRN's part of their ?governor mandatory and governor designee mandatory? CAP-EAS distribution. Federal action is needed to secure spectrum for LRN's where no dedicated or ?shareable? channels are available within of local government telecomm resources.
  • Broadcast top management has to be brought in now at the LECC and SECC levels to make sure solid relationships are built with the state and local emergency management communities for CAP-EAS. We as engineers can only do so much. We will still be needed to hammer out details, but, like any high level negotiation that goes beyond engineering concerns, the top dogs need to be directly involved. Emergency management needs to know broadcasters really need their partnership to make this work.
  • State Broadcaster associations and their national organization, NASBA, have already helped, reaching out to government, but much more needs to be done. As direct representatives for station management, their continued support is vital to get CAP-EAS working right in more places, and for more issues. Specific issues needing immediate attention: Governor level mandatory EAS and regional agreements between neighboring states.

Barry, keep up the good work! I can only hope that your editorial gets read in some key Beltway offices and maybe even gets reproduced in other media! Maybe you should produce a video version?
Richard Rudman
Vice Chair, California SECC
Former Trustee, Partnership for Public Warning
Past President, SBE 1985-87

Jerry Mathis - - 9/5/10

Well said, Barry! It's a large mouthful, but it all needs saying.

Personally, I don't have much confidence that the newly designed CAP system is going to help matters much, if indeed at all. It still is based on the "daisy-chain" delivery system, and not all stations are going to forward the messages.

The Government will be responsible, even if they don't accept it, for all the problems and failures that will happen with this system. I say "will" because it's not a question of "may". ISTR that when reforming the EAS was first proposed, the Gov't put out a call for suggestions. When industry people who KNEW how it should be done, like Clay Freinwald and Richard Rudman, showed up, they discovered that the Gov't already had a plan in mind, and the so-called "hearings" were simply window-dressing to meet the requirements of the law. Which to me proves that Gov't is NEVER the solution, only the problem.

We can only make the best of a bad situation at this point, as Richard suggests in his reply to your editorial. But for me, at least, it makes me wish for a lot less Gov't  "help" to our industry. Look at the current Royalties mess. Gov't can't get ANYTHING right.

Jerry Mathis

Mike Shane    9/8/10

At first I, too, thought mandating an FM radio in cell phones was a good idea.  Now I think the NAB is wasting its bullets.

Recently I purchased a little wear-on-your-arm FM HD radio for $35 through Eric Rhodes's fine publication.  It's a great little radio.  I don't use it much.  Most of my radio listening is done using a speaker, which this radio is too small to accomodate.  But if there isn't a pair of headphones plugged in - or I guess a reasonably long length speaker cord - you don't get much reception even in the midst of Omaha, with it's 9 or 10 class C FM stations mostly all transmitting from the same location!

People do use some form of headphones with their cell phones.  Thing is, they don't plug them in with a cord.  So the antenna to pick up broadcast radio with will have to reside inside the cell phone.

(By the way, I note that when I do listen to a radio station on my BlackBerry by way of a streaming app, the little internal speaker sounds pretty good, but that still doesn't solve the antenna problem.)

Not only will AM operators not benefit from this idea: they (we) don't have a prayer.  It's hard to find ANY radio manufactured today that does a halfway decent job of receiving AM.  A loop antenna could probably be fashioned to fit inside a cell phone but feature this: the phone is a little computer.  What do computers in proximity to the antenna do to AM radio reception?  Never mind that most people (at least the ones I run into) don't understand or have forgotten the concept of turning the radio to get the best reception of your AM station.  Can't imagine that working very well with cell phones.

So what's the answer for broadcasters?  Well, I have two ideas.

First, get in front of the parade on making your stations' audio chains available to smart phone users.  There are apps already developed out there for which you have probably already been pitched by an e-mail blast.  These things can be pretty cool.  My company's app will scroll the song lyrics on the screen for you when they are available.  Now, I realize the cell carriers are wanting to increase charges on data, but we'll just have to see how that shakes out and I don't believe one should let that slow one down or stop one. 

Second, we all need to kick the NAB - and probably some broadcasters - into the 21st century.  What we commonly call AM and FM radio is an old, reliable technology.  Problem is it's an old, reliable technology - with emphasis on "old."  Believe it or not, there are new, reliable technologies out there which are becoming more reliable all the time.

To further expound on that last line of thinking, I hark back to 1981 when I first heard of the breakthrough in mobile telephony known as cellular.  I have only a rudimentary understanding of it, still to this day, but as I understand it, it turns the typical mindset about power on its head.  Instead of having a really, really powerful transmitter addressing many, many receivers over a wide area, there are multiple less powerful transmitters addressing way fewer receivers each, usually only one at a time within a cell.  As well, the transmitters have the ability to know whether a receiver is connected to them or not.  Although that is a side issue for my point here, that very thing is what enables the efficiencies of the system in that the transmitter can know how much power it needs to use to reach the intended receiver. 

It's a quantum shift to apply this technology to broadcasting (although some low power unlicensed AM broadcasters have tried a low-tech version of it) but perhaps we need to be thinking in that direction.  Something called the phase-locked-loop (PLL) oscillator freed us to explore and utilize frequencies higher than we ever thought could be made economically feasible.  Broadcasters should have been in the front of the line for allocations up there but were conspicuously absent.  In fact, they resisted attempts to drag them up there with a new "digital audio broadcasting (DAB)" band and instead insisted on staying put.  Had they jumped, that transition would have been over by now.

So one way to apply this idea to broadcasting today is to have whatever presence is available to you on people's phones.  The streaming apps seem to be a good way to do this but it's only a little itty bitty start.  Maybe too little, too late.

It's time radio broadcasting had some kind of long-term technical plan in place, even if it involves piggybacking on the existing and future networks of the cell carriers.  Tech-savvy consumers will not continue to tolerate the difficult-to-understand foibles of Amplitude Modulation deployed on Medium Frequencies (think static, noise, 2:1 capture ratio, reduced nighttime power, directional signals not serving the same area at night - people do expect 24/7 availability these days).  And FM is right behind AM on this lemming's journey.

A plan is needed.  Else, we are going to lose to the future the most wonderful broadcasting system so far devised in any country.


At the Start of our Second (or Ninth) Year....

Last August, we started the BDR with the intention of building on eight years of work editing a print publication - since 2002. Some folks were not sure we would last out a year, but here we are, well on the way into Year Two of the BDR ... or nine years of being the Editor. Either way, you can understand the satisfaction, as well as the challenges.

The Broadcasters' Desktop Resource is predicated on several points:

  • Most people are under time stress, yet need information.

  • Many local resources are overloaded or drying up.

  • The Internet has made finding and reading information easier.

  • The cost of publishing and mailing paper has gone up a lot.

We could expand on each of these, but the point is that the BDR is here as a resource - and articles stay on-line, not disappearing onto a stack of magazines that, all too often, end up in the dumpster.

Additionally, we have the ability to utilize graphics (even video) and articles of different lengths in a way print just cannot handle. For example, the articles are generally in pdf format, so you can either read them on-line or print them out for leisure reading, use at another site, or filing for future reference.  

Your interest, comments, article submissions, and the fine vendors and  manufacturers who sponsor the BDR with the banner ads, etc., are what keep the BDR going. That and your recommendations to friends, so they too can check out the site and sign up for the one-time-a-week newsletter. Your referrals are valuable to us.

As you watch, some changes are coming to the site. The goal is to make it better and easier for you to use. We try to always listen to your suggestions and try to use them whenever possible.

Once again, we offer our sincere thanks to you, dear reader, for coming here to the site. For those of you who email, call, or otherwise contact the sponsors, a double thanks. In these days of multiple impressions from many sources, when you let them know you "saw them on the BDR" you have to know it helps us all. 

Please do keep an eye on the BDR. Some interesting things are coming!


NPR Drops the "Radio" label
... Are They Trying to Tell Us Something?

Over the past month or so, National Public Radio has decided to press ahead to something new, apparently even if it means leaving their core constituency behind.

After their CEO announced at a meeting in California last month that broadcast radio will soon (she said between five and ten years) be replaced by Internet radio, many NPR stations began wondering what was next. Already, NPR had begun competing with the stations that provide about 2/5 of its budget, placing programs and other material on their Internet site. Telling people that they did not expect to see radio towers in ten years was not reassuring.

Additionally, in the name of being "modern," Vivian Schiller has decided that three letters is enough: NPR ... no national ... no public ... no radio.


Commercial broadcasters have alleged for some time that NPR is out of touch with the rest of the industry. More than a few feel that if it were not for NPR members, HD radio would have already died on the vine. (It is true that NPR, among all entities, has used the secondary channels well for real programming that is not otherwise heard.)

But this decision might just be proof of the accusation.

To claim that Internet feeds will replace broadcast any time soon is just hard to swallow by almost anyone outside the Beltway. Internet bandwidth and distribution, especially wireless modes, are just not ready - nor will they be anytime soon - to replace the broadcast model.

And, what are the local NPR stations to think? All their effort in raising money and contributing programming is merely so NPR can move away from them and serve a different audience? Simply stated, this does not sit well among the members.

Even as smart operators are re-examining the wisdom of the lemming rush to automation and voice-tracking, NPR would do well to stop a moment and remember where the bulk of their listeners - and money - are coming from.

Yes, broadcast is in a bad way recently as the consolidators' sins have redounded upon the industry. However, cell phones and iPads, etc, are nowhere near taking over the brunt of distribution for the majority of listeners - even if you ignore the sound quality delivered. The phone companies and cable systems claim there is no profit as yet in distribution - and until there is, no company nor government is going to spend the money.

One can only hope that the suits at NPR will wake up and remember where their roots are. It would be tragic if this current trend damages the local stations, yet leaves the national organization starved for the new audience they think they will get. If NPR and the members are crippled by all this, Ms. Schiller and her friends inside the Beltway will have done a great disservice to a lot of dedicated people.

Submitted Comments:

Gary O. Keener -  - 8/3/10

I agree with the other commenters on this topic, but would point out to them that "local" radio became mostly a myth long ago, probably in the 1980's, when satellite and computers came along. It's just always been cheaper to not create programming yourself. In my day, you had no choice. I'm involved in a struggle over this right now.

So the business is busy testing the limits of how far it can go in the direction of being non-local and still telling the audience it's local. The real battle is over "local". Is that, however defined, important now? Some say yes, others could care less. To me "radio" = "local", and satellite and internet "radio" are more properly to be considered "audio programming services" unless they actually have significant locally-produced content.

NPR affiliates mostly flunk the "local" test, although not completely. So they're in a gray area. Most commercial broadcasters (by number) completely flunk the "local" test and have no reason to have a license, in my view. In the future, they won't need one. But is that a bad thing?

Hal Kneller -   7/9/10

Personally, I don't find the change of using NPR rather than the longer name offensive if it were for the reasons that IBM, KFC, RCA, HP, SUNOCO or others have shortened their names.  NPR as three letters can still be a powerful radio brand and most people referred to is as NPR anyhow.  Most writers called it NPR although probably somewhere started off their writing with the full name and didn't use it everywhere thereafter.  NPR itself has encouraged it both on their website and on the air with the logo and "This is NPR - National Public Radio" for a long time.

When I was chief engineer of an NPR station back at the time when XM and Sirius were independently starting service there was a lot of push back that NPR, PRI and MPR (now American Public Media) were taking money received from member stations and going into competition with them on the "birds".  There was a lot of angst about that.  They were even trying to figure a plan to allow some revenue sharing with local stations based upon zip codes (I don't think this ever materialized, I don't know, I left the stations shortly after the satellites were on). 

While I certainly have the view that you cannot stop progress, and that if you want to succeed in the long-haul you need to be part of it, comments made in California by the NPR CEO and apparently further de-emphasis of radio (comments given by her in the change to NPR only) which has to be their core means of distribution today must be troubling for development directors and general managers at member stations.  I think it sends the wrong message.  Join in and develop the new media and promote new media but you don't have to make the current ranks of member stations and their massive contributions (financially and programming) feel diminished (perhaps irrelevant) in the process, at least not until those new media appear to tip the scales away from the traditional as reported by PPM or by dollars (which is nowhere even close today on either count).  My employer at the time was paying NPR close to a million dollars a year for programming fees back in 2000 (and I'm sure more now) and it wasn't even a top 50 market station.  Compare this to most affiliates who get most of their network programming free in exchange for running the network spots!!

Therefore, I think it reasonable if the GM's of NPR member stations are upset about the overall repositioning of NPR disfavoring radio, they are in the delicate position of being able to do something about it.  They can either fire their leader or instruct her to tone it down while continuing the pursuit of new media development and encouraging localism on the part of the member stations and their many valuable contributions locally and to the NPR organization.

Grady Moates -  7/11/10

lemons or lemonade -- you decide

Anyone who thinks that the "new digital delivery systems will never reach critical mass" needs to re-think things a bit.  On The Other Hand, anyone who thinks "towers will be obsolete" also needs to re-think things a bit. 

If NPR and its member stations do it right, the digital connections to NPR programming will be made through the _local_ digital streaming servers of terrestrial-broadcast NPR member stations, for the obvious reason that the local element is a key part of the menu that listeners are seeking when they "push the button" to get NPR.  The technology exists to redirect stream requests

at a central server (NPR's website) to somewhat-more-local sources of the programming simply by examining the IP address of the requester.  This technique might not redirect to "the closest" NPR member, but it'd be a member providing local content from a lot closer than Washington, D. C.  For all I know, NPR is working on this technology right now. 

Under this model, Direct Satellite Broadcasts will, during the local news avails, promote the fact that local NPR stations "are now providing" up-to-the-minute information about goings-on in their neighborhoods.  The NPR direct-from-satellite programming becomes simply a sign-post that points the way to a higher-quality feed with additional local content that is available from that friendly, nearby tower over there.  Of course, success of this model depends upon [a] local stations _actually_providing_ a higher quality signal, and [b] local stations _actually_providing_ well-presented local news and public affairs programming. 

The clamor for FM tuners in hand-held devices is another initiative that works toward this goal.  Remember that EAS (or whatever comes after) is one of the main reasons why FM tuners should be included in hand-held devices.  The hand-held device with an FM tuner in it can be programmed to always be listening for the data bursts, even when it's not being listened-to, a factor that ties localism directly to safety-of-life.  Besides, there is a vocal faction among us preaching that satellite radio is a walking dead man, simply because it doesn't have positive cash flow and doesn't look like it's going to have positive cash flow in time to save itself.  Eventually, the bucket of cash will empty, and the bird will go dark, or become re-purposed. 

I believe:

[1] that digital delivery through something like an internet, both wired and wireless, is the wave of the future, and "resistance is futile". 

>>> Please don't read into that statement that I also believe that IBOC is our saviour.  I am not commenting either way on that subject in this posting. 

[2] that CPB funding of Public FM stations' rollout of IBOC _is_ a major factor in whatever amount of success Ibiquity has enjoyed over the last 6 years, and if you pull CPB support out of the equation, it quite possibly might have already died.  Remember that multi-casting was entirely an NPR initiative, and the brouhaha generated by that lengthy discussion got more main-stream press than anything else that Ibiquity did. 

[3] that Audio-Only programming will always have a place in the marketplace.  There are just too many human activities that will not allow the eyes to be engaged, but almost _require_ engagement of the brain with external stimuli to keep boredom from reducing productivity and safety. 

[4] the average human does not want to spend the time it takes to do their own programming of audio-only devices such as iPods; kids have the time for that, and that's why we've lost them, by-and-large.  However, adults have so many demands upon their time that programming a Zune simply gets done less often.  When the pocket-music-machine gets stale, the consumer will turn on a radio or an internet stream to fill the time, and that is our opportunity to be better than their alternative. 

All this boils down to the plain fact that radio isn't working as hard (less effort is being expended on developing compelling programming) as it did back in the '60's and '70's, and _that's_ why it's failing. 


Is it really time to consider
using Channel 5 and 6 for Radio?

FCC Commissioner Mignon Clyburn put forward the opinion that the FCC ought to give thought to whether it was a good idea to make room for daytime AM, LPFM and other non-commercial stations on television Channels 5 and 6.

Noting that operations have proven to be very inefficient for digital television, Clyburn said "it is to take a serious look at where these services [AM, LPFM, NCE] fit within the overall spectrum plan, and that Channels 5 and 6 may be a good home."

Of course, this is far from a done deal. The comments of one Commissioner do not Policy make. And, there are so many details to be put in place, lest it become little more than an Oklahoma "land rush" that favors only the well-connected or the application factories.

It is worth remembering that many of the changes were the direct results of intense lobbying by some special interests - resulting in direction from Congress that the FCC do certain things - followed by the laws of unintended (or not) consequences. Personally, I am not unconvinced that some of these initially hidden consequences were not
in fact "chess moves" intentionally set in motion by some of special interests.

For example, whatever comes should - but will probably not - be carefully constructed. Otherwise the special interests will grab any new bandwidth before local communities and organizations even realize it is there - and the script kiddies and lawyers will work overtime to pervert the intentions of any new Rules.


Yes, the AM daytimers (and stations that are "effectively" daytimers) generally are in need of some relief. However, the way the expanded band developed showed how easily those intentions were subverted,
with some making millions find a loophole to sell off the first x-band stations.

Another group that desperately needs - and deserves - help is the Native Americans, who are often locked out of being able to provide service to their Nations, due to the number of signals from markets and  suburbs that often are quickly rolled out, often preventing any effective coverage to some areas as large as Connecticut.

As the proposals are developed, there will be many attempts to build networks of translators and satellators. These, in general, should be banned, period. Especially with Internet streaming and other modes of distribution coming on line, there is no valid reason to take limited local bandwidth and give it to anyone without a local studio, capable of providing local service, especially in emergencies.


Nevertheless, it is refreshing to see someone at The Portals thinking about giving something to broadcasters, instead of taking it away.

Clearly, there is a long way to go. The instant proposals are just that - proposals. Unless the majority of Commissioners move on them, they will languish on the pile of good intentions. And we can be sure the special interests will add a lot of their desires to the mix.

Some interests seek the return of the Three Year Holding Rule, and the 7-7-7 Rule. Both of these may hold some good, in some fashion, but the changes in society probably mean those Rules hold less value than something encouraging - even mandating - some local, live operations. (Not 24/7, or even 12/7 ... but something that makes the station more a part of the community. That would be counter to everything we have seen in the past 25 years.

As we work our way through this "tunnel" of proposals, let us hope that not only is there light at the end of the tunnel, but that it is not a train headed to run us over!

What is your opinion?  Use the "Contact" link at the bottom of this page and let me know.

Submitted Comments:

Lewis Downey - 

I am in favor of serious study of at least the ch 6 spectrum be available for non-profit/community broadcasting. It's a tough hill to climb of course because of no receivers. It might be necessary for the FCC to mandate that new receivers be built to cover the new spectrum. In spite of the predicted demise of radio every filing window demonstrates the continued irrepressible demand for new signals.

Broadcasting can be there in emergencies. But, will it continue to be there?


There is a tug of war going on at the FCC. Actually, there are several tugs of war going on. And that is the part that frustrates broadcasters.

It has been clear for years that the FCC, prodded by its Congressional masters, sees broadcasting as an increasingly smaller part of their concerns. With cable and satellite penetration now covering the vast majority of the population, the bandwidth taken by TV transmitters is being prepped for a prime real estate grab and sale.

Never mind that many of the frequencies, especially the low band VHF, is not suitable for much else. Never mind that with a $1.2 trillion (at last count) budget deficit, a billion dollars or so from yet another auction would be little more than a drop in the bucket. Even now, wireless microphones on the 700-800 MHz band are being outlawed, in preparation for selling off the bandwidth to the wireless industry.

The Congress, the FCC, and politicians from one end of the spectrum to the other all see wireless as the "future" of communication.


Yet, someone is not listening to the wakeup calls. The floods of the past week once again showed that cell phones, Internet, and cable TV are useless when a river floods rapidly (the news reports indicated that the river in Nashville jump several dozen feet in just a few hours!), it was radio that provided the broadcast news and information that people in the disaster zone needed.

Sure, WSM and some other stations were flooded out of their studios. Even some transmitter sites were ill equipped for the water's rise. But once the power goes off, many of the alternatives are gone for the duration, while radio can get back up and running rapidly.

WSM radio set up a studio at the transmitter site. Others have made disaster plans, to use auxiliary sites - or even portable transmitters. With a little ingenuity, a station can set up with a card table, portable generator and little more than a coat hanger - and reach much of the market - all in a short time. Meanwhile, once the power and cell site batteries are gone, all the reverse 911 in the world is useless.


In the recent earthquake in Chile, emergency managers finally had to admit their error in putting their hopes in the Internet and cell service to keep the lines of communication open. It was radio that managed to get the word out, once the politicians and bureaucrats stopped trying to force information down a broken tunnel.

Ditto for Haiti ... and for the tornado damaged towns in the mid-West. Radio was there. The other modes were "not available."

All of this leads to us back to the ongoing efforts by the FCC to grab spectrum from broadcasters to auction off. When it is all gone, how does the government expect emergency information to get out?

By the way, there are bills in Congress that essentially says FCC Commissioners each "may have" a engineer on their staff. The question is whether they want an engineer to tell them inconvenient truths about what their actions are doing to the broadcast media.

The NAB Radio Board is, at least, concerned with the frequency grab. However, the high level of automation at so many stations deserves their attention. In too many places, there is no concerted effort to encourage stations to become key local content providers - the place listeners turn to for news and information - especially during emergencies. Instead, too often all listeners get is the automation playing the hits. The result is a general attitude of listeners that - aside from a few Full Service stations - nothing will be heard of value to them.

Broadcasters, the FCC, and Congress all need to stop and think about the best ways to reach people, especially in times of disaster. Instead of auctioning off bandwidth, the FCC should be encouraging stations to enhance their community service - and planning well to survive disasters - so they can continue to be the voice of communication.


Earlier, we asked the question: Is this the year to skip NAB?

The evidence is that those who did missed out.

Check the NAB report, coming together at


I've been hearing from many folks that have decided to skip the NAB Spring Show this year. Some are planning to attend the Fall Show (in DC) this year, as closer and easier. Some are being discouraged by their companies.

A major aspect of whether to go or not is based on certain attitudes and habits, developed over the years. As a veteran attender for well over 30 years (eek!), I've developed my own attitudes and habits - many of which help me get the best out of the Show.

This year, the NAB is also counting on our curiosity - for the first time in several decades, the North Hall is no longer the Radio Hall. Radio manufacturers are mostly sprinkled in the Central Hall.

Let's start by noting some of the "habitual" attenders. In general, folks who go to NAB fall into five categories.

  • Companies who go to show/sell their wares.

  • Broadcasters who are contemplating purchases.

  • Companies who go to show they are still in business.

  • Broadcasters who are looking for an education.

  • Broadcasters on a junket.

Perhaps that last is overly-generalized, but from my very first NAB Show, I can still remember my stations' GM sitting in the bar at the Hilton virtually any time he was not at dinner or a show.

Yes, there are some who are there specifically to see a particular product or manufacturer, leading to purchases on the floor. And some manufacturers and vendors are so tired of the physical, mental, and economic costs that, by Thursday, they no longer even wait for the blast from The Who before packing up. 

But that somewhat negative view is outweighed by the positive aspects of going to the Las Vegas Convention Center.

First and foremost is the chance to see not only the equipment, but the folks who make it and support it. There is nothing like the opportunity to get the feel of a console or have someone carefully guide you around the automation platform, so you know how to get the most out of it back home. There is just no way to beat a "hands-on" experience.

At the same time, making those personal contacts is invaluable when you need tech support. Although you might seem like you are lost in the hundreds and thousands of booth visitors, I have found that the great companies and people make it their business to remember as many of these contacts as possible. There are few more encouraging comments you can get on the phone when calling a company than "Yes, I remember you. You were the one looking to .... "  I've personally had this response many times over the years, and it made my relationship with some companies strong enough to overcome some of those inevitable issues that come with any product.

And then there is our Lunch Gathering on Tuesday. Now in its 18th year, it is a chance to meet folks from around the country in a less packed location.

Overall, the ongoing education on what is new and improved can save stations a lot of time, money, and grief, as they adapt to the changes in the industry.

Seeing such benefits, you would think that attendance at the NAB Show would be a key part of a broadcaster's year. This is especially so in a year when hotel rates are rock-bottom. There are more than a few hotels with rooms under $40 a night - some well below - making that a non-issue. Travel and food can be had for modest amounts.

Unfortunately, some short-sighted managers are trying to save a few pennies by keeping their personnel home this year. Sometimes the story is "we have no budget" or "we're not buying anything this year" or "there is no one to cover your job" or "you went last year - what do you need it for?" Most of these are lame excuses.

As proof, I'll just mention this, from my third NAB show: a contact made on the floor resulted within a month of a savings of more than $1500 (in 1980 dollars) when I learned information about an equipment upgrade that we could get at no cost. Another year, we avoided buying a product that proved to be a disaster in the field - because I could put my hands on it ... and ask questions about it ... on the floor at the NAB Show.  

By the way, the Fall Show is no substitute. There are far fewer exhibitors - with much less to see.

Will you make it to the 2010 Spring NAB? Even if you make it in for just a day or two, you will not regret the decision.

I hope I'll see you there!

IBOC at -14 dBc or -10 dBc  


The FCC Media Bureau issued an order which, in 30 days, should allow many HD stations to increase their power fourfold, assuming there is enough headroom in their transmission plant. More power is potentially available subject to interference studies.

Some stations, especially NPR affiliates who have invested heavily in digital transmitters, welcome this as a way to overcome what has proven to be less solid coverage than originally anticipated. Some studies by NPR and others seem to indicate the power increase will more closely match the analog coverage contours. 

Others worry, with justification, that the increased power will cause a great deal of interference. In many places, including the large coastal markets, where stations are spaced closely, first-adjacent interference could be a problem. 

The nature of HD Radio and the unique arrangement the FCC permitted - a proprietary system made "standard" - has been discussed, argued over, blessed, and cursed extensively over the past few years. 

The power increase will definitely provide fuel for a lot of these arguments to be revisited.

Suburban "rimshot" stations may well find themselves elbowed out of larger markets, some non-comms will find some of their donors no longer can hear them, and other unfortunate results are sure to come. Yes, HD stations will have more reliable coverage. But, given the relatively small number of receivers in the field, one can legitimately ask if this was the right time for the power increase.

But, if not, when is the right time? 

At a time when the radio industry is suffering greatly, even if the HD channels find an audience, is there enough advertising money to support the creation of content that will attract listeners?  More to the point, will the stations running HD invest to attract an audience. Many observers suggest that radio is allowing itself to be bypassed by Internet and Wi-Fi options. Some of them feel radio needs HD to combat the new competition.

Others posit that the FCC could have prevented this situation by placing digital radio on the frequencies used by TV Channel 6. There would even have been room for AM daytimers and LPFM stations to relocate - especially if care was taken not to allow the band to fill with satellators - and there would have been enough power, spacing, and reason for people to buy the new HD receivers. 

My view is that - like it or not - we have what we have. Stations that have invested and can turn up their power, should be able to do so - but there should be very careful monitoring of interference, with quick resolution of complaints. The FCC should pay close attention.

For various reasons, perhaps fewer stations than expected will make the increase, allowing for a wide variety of real world tests of the effects of higher digital power levels. That may yet provide some useful data for making reasoned choices as we move along. 

On the other hand, if many stations do up their power, we will know for sure which of the claims and counter claims were right. 

Regardless ... digital transmissions alone will not revive broadcasting. To paraphrase someone "it's the content, silly."  

(What is your opinion?  Use the "Contact" link at the bottom of this page and let me know.)

- - -

The late James Quello and the FCC


I never really knew James Quello, longtime Commissioner at the FCC, and product of Detroit radio - in other words, a real broadcaster. However, by all accounts he was generally liked and respected. (Brief obit here)

Of course, not everyone appreciated Quello's positions, especially those on the for edges of the political spectrum: those who wanted either to use the FCC to either put heavy demands upon broadcasters or to "push the limits of taste" to the maximum. By all accounts, Quello was a pragmatic man, who understood broadcasting in a real world.

Many in the industry today lament that the FCC seems to be more political than ever before. There is no question that the FCC must do its master's demands - and Congress is the FCC's master. However, political concerns are clearly ascendant - from selling off bandwidth and focusing enforcement for the purpose of funding federal operations to the recent efforts to re-impose the "Fairness Doctrine" or the decision to bless a single, proprietary system for digital transmissions.

That none of the current Commissioners have experience in running a broadcast facility is unfortunate. While the FCC has a lot more to handle than broadcast, having a Commission made up of lawyers and political appointees alone tends to result in decisions that sometimes ignore the physical laws of transmission. Conflicting decisions on de-regulation and increased scrutiny of everything from minority staffing levels to the nature of talk radio have thrown veteran broadcasters to the extremes of long hours or no jobs. 

Would the extreme consolidation of the industry have been permitted if the Commission had more Jim Quellos? Mirroring much of modern society, a few have become very wealthy running the large companies while thousands had their careers suddenly terminated due to "budget cuts." 

As I said, I never met James Quello. However, I get the impression he would have done all he could to maintain a strong, local broadcast industry, much as he presided over at WJR. If it were up to him, he would never have allowed the Enforcement Bureau to become the enemy of the industry. The current Commissioners could do a whole lot worse than learn from the example of James Quello.

What is your opinion?  Use the "Contact" link at the bottom of this page and let me know. 

- - -

The EAS Express continues:


The Statewide, end-to-end EAS test was conducted in Alaska last week. It was generally pronounced a success, even though the system failed in several aspects. Some were equipment failures, some appear to be related to the change to automated stations - lack of a live person caused a few issues. 

Of course, that is what tests are for. (The FCC EB kindly announced they were not contemplating fines for stations with problems - but after the mess they made of the KWVE situation, it was sort of irrelevant.)

Representatives from all the interested state and federal agencies were on site, and watched the test and the way it "propagated." We are told that a true national test will be held later this year, presumably incorporating the lessons learned from Alaska.

We hope that the experience in Alaska will foster a successful national test - and indeed bring the EAS in line with the needs of broadcasters and emergency managers, so they can have confidence the system will work when needed and activated -  if the emergency management community and broadcasters can find a way work together.

Of course, even before the analysis of the Alaskan test is finished, someone in DC has already proposed a Rulemaking to require a national test. 

Oh ... yes ... is it significant that the FNPRM is marked as "EB Docket No. 04-296" ??? 

- - - 

Is Radio Ready for 2010?  Are You?


The news this week has seen two radio groups file for bankruptcy protection - Citadel and NextMedia. 

Neither were big surprises. The recession has brought down many companies in many industries. Radio is just part of the wreckage. Indeed, the Citadel bankruptcy was pre-packaged, with the outcome all but guaranteed when the paper was filed.

While many would like to see the layoffs knock on the CEOs' doors, the fact is that the banks are not broadcasters. Their main interest will be to cut costs, so they recover their money. On-air content and staff are secondary, along with the physical plant.

However, since radio is of special interest to us, it is that "collateral damage" that horrifies so many of us. Scores, even hundreds of our friends and workmates have been laid off - many with virtually no hope of finding employment. And, one thing is certain to come from what we might begin to call the broadcast bankruptcy season of 2010: we will see more layoffs.

Still, I am preaching to the choir, am I not? Few would argue that we are about to enter a Golden Age of Radio. 

Nevertheless, it is those employees - whether on the technical side or operations - who prepare now to handle the work ahead have the best chance of surviving the months ahead. 

By preparation, I mean knowing (or learning) how to run an efficient department in a professional manner. While engineering should not be primarily a profit center, there are opportunities in operational savings or site rentals that can benefit the company. Wise managers will make sure to hang on to these employees, even rewarding them within the ability of the company.

That said, no one should have to work 70 hours + a week. No one should have to submit to being harassed or denigrated, no matter how much pressure is on the GM to do much more with much less. Part of his job is to protect and encourage you to do your best and gain a measure of job satisfaction.

Bad managers, on the other hand, will try to hire cheaply and push their employees as hard as they can. They may get away with it for a while, but eventually the excessive cuts in the technical budget will harm the station. That is a bad place to work.

So, we encourage everyone to take their future into their own hands. Know your worth. Do not let anyone try to take that from you. Realistically evaluate your job and company to see if you are in the right place. Finding a good job takes effort - and more time than usual - but they are out there. 

At the very least, plan to make 2010 a good year for yourself. With that attitude, you will succeed.


- - - - - - - - - - - - - - -- - - - - - 

December 9, 2009


Some trade publications are commenting upon the FCC Enforcement Bureau’s (EB) “waiving” of the $5,000 fine assessed against KWVE-FM for a botched EAS test as good, even calling it “sensible action.” This is just plain wrong. Let me tell you why.


On a Sunday in October 2008, KWVE’s operator started to run a Required Weekly Test. Due to his misreading the automation system’s labels, he got confused, sent the Monthly Test, then failed to send the EOM.

A complaint from a viewer on the local cable system led to an inquiry. Some Staffer sitting at a desk in a dark corner then decided that “Revenue Enhancement” was more important than actually understanding the situation and reacting to it reasonably. Using the excuse of “the Letter of the Law,” the Staffer – apparently a lawyer - ignored both the station’s explanation and the intent of the Rule, and twisting the English word “willful” into a legal joke, issued a Notice of Apparent Liability (DA 09-2053) for $5,000. (Those of you who are familiar with the Hitchhikers’ Guide to the Galaxy might think they recognize a Vogon Construction Fleet Captain – although there was no poetry.)

It was a failed test. KWVE, an LP-1 station, has continually trained its operators and run many tests over the years. The station’s Chief Engineer is the Chair of local operational area’s EAS Committee (LECC). And, oh yes, the EB’s actions alarmed every LP-1 and LP-2, lest they ever make such mistake.

No matter. The legal “process” appeared to be more important.

KWVE, every state broadcast association, and many individuals wrote the FCC to protest this silly attitude – and the effect it would have on the relationship between stations and the FCC. Many LP-1’s and LP-2’s began reconsidering whether they wanted to remain volunteers in a system that penalized stations that stepped up to the plate to serve their areas. I know this for a fact, as more than a few have told me so.

Meanwhile, the EB went into hiding, using all the legal weasel-words available to say they were “just doing our job.” Calls and email to the EB to clarify the issues were not even acknowledged.


Someone at the EB clearly is unwilling to deal with this in a straightforward manner and hopes the issue will go away.

In return for magnanimously waiving the fine, the EB has “admonished” KWVE and demanded they file more paperwork to repeat what they already have stated regarding training and protocols to comply with the EAS Rules. This is contained in DA 09-2421

By doing this, the EB figures it does not have to answer the issues raised by KWVE in their response to the NAL. It just declares them moot. All the sputtering about how essential the EAS is “given the national interests at stake,” means little if this “waiving” of the fine does not address the legitimate concerns of broadcasters.

Actually, what we have here appears to be little more than bureaucratic damage control by the EB. The way it was handled is just plain dumb, showing that some FCC EB Staff are more concerned with matters other than helping broadcasters and the EAS.


Now, I am not in the habit of being overly critical of the FCC. In 30 years of writing, I have tried to understand the agency’s role and the various issues it faces. The FCC is a large agency, with many responsibilities – quite a few of them driven by its political masters. Many good people there try to accomplish their jobs in a professional way. A few are, unfortunately, act like over-zealous cops looking for something to cite.

Broadcasters often lament how the FCC seems to have pushed engineers out in favor of lawyers. Dealing with the FCC is now almost always frustrating and expensive.

The whole process reeks of non-communication. If someone from the EB had simply picked up the phone and contacted KWVE’s Chief Operator for an explanation – or even really read the station’s written reply - a lot of paperwork and angst would have been prevented. But, instead, someone decided to play bureaucrat and push the button on the “machine,” focusing on the technicalities of the legal system, because it was easier to do that than actually solve a problem.


Was KWVE negligent? Did it do something wrong on purpose? Neither was the case. The evidence is that KWVE is acknowledged as an active participant in the EAS and works to train their operators as much as possible.

Very few LP-1’s or LP-2’s fail to take their responsibility seriously. Manpower issues in the industry mean that many engineers stop what they are doing to fire off the tests, to reduce errors as much as possible. But they, and their operators, are only human. Mistakes will happen.

If broadcasters have to worry that any time a botched EAS test generates a complaint and a fine, there will be resignations of LP-1’s and LP-2’s, leaving, in many cases, inferior facilities to send out alerts during emergencies.

Last month we called on the FCC to make a clear Policy statement to broadcasters as to their intentions – and what can be expected of the EB in future. Thus far the FCC has not done so.

We repeat that call.


Perhaps someone in the EB should be admonished.

If you have an opinion, you may wish to communicate it to the fine folks at the FCC. Although the EB remains aloof, other Staffers have told me they do not agree with the EB’s actions. They also say that the Commissioners themselves are interested in hearing the concerns of broadcasters.

This is a very important time to make your voice heard. Otherwise, we might be witnessing the destruction of the EAS by bureaucratic Vogons.


While, I will not suggest exact wording, lest someone view it as a letter writing campaign, perhaps you might want to discuss one or more of the following:

  • How this situation demonstrates how easy it is for tests to fail, even at a station with an above average commitment to the EAS and a training program.

  • Your personal commitment (if you have it) to EAS, and the desire to strengthen it - not kill it off.

  • Why RWTs are useless.

  • A desire to have Part 11 (not to mention Part 73) excised of lawyerese English and make plain its meaning.

  • Whether or not all RMTs should original from local governmental EM agencies – and put the responsibility there.

onSome have gone further, even to the point of sending a note to their LECC and SECC indicating a desire to resign from the LP system if the admonishment is not lifted and a clear statement about how the FCC plans to react to future botched tests.

Address your comments to:

I would suggest you send a note to the EB, but somehow I do not believe they want to hear from anyone nor address this problem straight on.

You should also copy your comments to:

  • Your State Broadcast Association - Follow this link to NASBA for your state association. 
  • Your Local EAS Committee.
  • Your State EAS Committee.
  • (I would be pleased to receive your thoughts as well.)

Please - do not expect others to do this. Even a short note is better than none.

Please - let the FCC know of your concerns today.

Barry Mishkind
Editor the BDR

LINK: Some comments from readers  - including Richard Rudman's and Adrienne Abbott's comments 


- - - - - - - - - - - - - - -- - - - - - 

First of all, let's pause for a moment to remember Louis King, Founder of Kintronic Labs, among his other accomplishments. Mr. King, his son, and the entire staff have build a business based on excellent engineering and workmanship - and a business sense that values customer satisfaction as much, or more, than making every last dollar.

Those who knew Louis King know what the industry has lost. Yet, even those that did not get to know him personally still know Kintronic Labs is a quality operation, in all senses of the word.

That is a legacy of which to be proud. 


On the HD Radio front

The economic downturn continues to stress the broadcast industry, just as it does the economy at large. However, even as the financial issues ( and possible bankruptcies) play out, the troops in the field continue their struggle to produce high quality programming and maintain clean, solid transmission systems.

For that reason, it is important to be aware of the current effort by NPR and Ibiquity to ask the FCC to quickly approve a blanket 6 dB increase in FM digital transmission levels. And, they would like even more. Its supporters hope it will go a long way toward solving the annoying dropouts that afflict IBOC reception. The NAB supports the move.

Not everyone is convinced that HD is the solution for what ills broadcasting. Some folks worry that there is already enough interference being generated by digital broadcasts. And for many listeners, the jumping (blending) back and forth from digital to analog makes it hard to get solid reception, especially when mobile.

Still, NPR and its affiliated stations have been in the forefront of digital broadcasting; some excellent use of the subchannels has been made already. In some areas, even more listeners have HD radios than broadcasters do. 

Whether or not someone is for or against HD radio, the ongoing need to understand the technology remains. Seminars at the NAB shows and by manufacturers like Nautel (look here) provide needed information. And, everyone should understand the ramifications of the proposed power increase. Improving the whole band is important, not merely the facilities of a few.

... and then there are those who wonder if AM is being completely forgotten in this exercise.  

Barry Mishind   


October 22, 2009

In the past several weeks, broadcasters from all parts of the country have been reacting to the $5000 NAL (Notice of Apparent Liability) issued to KWVE, San Clemente, CA for a botched EAS test. 

The members of NASBA, the National Association of Broadcast Associations signed on to a letter to the FCC, asking for the fine to be set aside. Many stations or groups have made comments as well.

Yet, in some ways deeper damage is being done than just some arbitrary fine being assessed.

For KWVE, their legal bills have already exceeded the proposed fine. 

Worse, many of the LP stations across the country have indicated their plans to resign as EAS primaries, if they are subject to such arbitrary NALs. This could cripple EAS in many areas.


EAS is, as most know, under attack from many directions, as people have many more diverse sources of information than they did in previous years.

With the growth of Emergency Management departments, in many places "kingdoms" have been built, and as with many bureaucratic operations, information becomes scarce. 

Even in the best of times, Emergency Management has many priorities, and dispensing information is not always at the top. This is why broadcasters and EAS are so important.

However, it doesn't help that, in may places, the Media has become an adversary, seeking to report any failure by EMs and their people - looking for a "Katrina/FEMA"-like scandal under every rock. Little wonder then that when broadcasters arrive, the "Media Relations" crew goes into operation, issuing non-informative releases and working to keep the Media away from the emergency. Every report you read about how some EM used "reverse 911" to "get the word out" says, between the lines, the EMs and the Media do not trust one another.

Similarly, although in some states, EMs have been recruited to work closely with stations, even initiating EAS tests and alerts, EMs rarely understand broadcast programming and the impact that tests and alerts can have on stations - both from the aspect of delivery (as in someone reading a statement in halting dictation mode), as well as the loss of commercial time. 

In at least one major city, local stations had to "take back" the EAS from a City EM department that did little more than send failed tests every month.

There are those that say EAS is permanently broken with this lack of communication. Without some unusual chance in attitudes, the lack of trust dooms the system in many places.


Those calling the FCC to try to get a handle on what is happening often reach some Staff who are concerned about the distrust the KWVE action has created and the lack of clear guidance for stations. But they are not in charge. 

Getting a clear statement as to the Commission's attitude toward the issue is harder. "We have to wait for the process to be completed," is the general answer. Sometimes, in my research, I have felt like I am dealing with captains in the Vogon Construction Fleet - and I've lost my blanket.

Nonetheless, the industry deserves a direct statement as to what Policy stations can expect to be applied in the future. Unless there is proven "willful" - in the English language, not legalese - failure to conduct a proper test, stations should be confident they will not be sanctioned.  

We repeat our hope that the Commission will do this - make a clear Policy statement - and soon. 

Barry Mishind   

Want to make your voice heard 
on this matter?

If you want to reference the KWVE NAL, the File Number is: EB-09-SE-137

For maximum effect, 

  • make it your personal comment, not a form letter.

  • keep your comments to the point.

  • Invite others to make their views known.


Feel free to click on “Contact” below, and let me know how you feel about this issue.

October 12, 2009


I may be embarking on a sort of mission. Perhaps I may be in danger of becoming a latter-day Don Quixote here, but I am going to try to do my little part to foster positive communication.

The essential question is: does every interaction these days between broadcasters and the FCC have to be adversarial? The current spark for this thought is the KWVE issue (full details here), but the underlying feelings have been growing for years.


Many of us remember the days when the FCC’s relationship with broadcasters was collegial, where it seemed that both groups’ primary interest was to help broadcasters better serve their community. Stories abound about how the Field Inspectors would come by a station and help them set their frequency or modulation levels, for example, without stopping to write a “ticket” for every little infraction.

On the other hand, if the station was not making an effort to stay “legal” – not keeping logs, or logs that were obviously falsified – all bets were off. But most experienced engineers have experiences where the Field Inspectors worked with them to solve problems. I clearly remember the night I answered a rap on the back door of a station, where I was doing vacation coverage, to find a Field Inspector’s vehicle backed up to the building. “What does your modulation monitor say?” he asked. In the next few minutes, he demonstrated that the mod monitor was out of calibration, helped us calibrate it, packed up, said good-bye, and moved on.

As you can see, I have remembered this for decades. I have had to, because this sort of encounter is probably no longer possible, given today's realities: the Field Offices' budgets and their marching orders leave much less for broadcast than in previous years. Broadcasting is a small part of their oversight – even if there is enough time and budget left for gas to go out and inspect stations – and often of concern only after an interference complaint. Yes, there are many good field agents out there who care. But their mandate seems to have been changed.


Therefore it will not be a surprise to learn that sometime later, at another station, a different Field Inspector showed up demanding to see all the contracts we had for our part-time announcers. Of course, there were no such contracts. He could not explain why he wanted them, nor what Rule indicated a need for their existence. We never found out exactly what he wanted.

However, he then announced that he was going to have to cite us for “excessive radiation” – 954 mV/m at one mile. When we noted that the Rules basically discuss the minimum radiation for each class of station, he moved on, complaining that the disassembled transmitter fan assembly (awaiting replacement) – in a locked building inside a locked gate - was against GEP (Good Engineering Practice). For good measure, he located a two-inch section of a radial that had become exposed.

Shall we just say that when he left, my view of the relationship between “us and them” was altered. It helped a bit when he called later that day to say he was not going to cite us for overpower, after all, as he had “read the meter on the wrong scale.” But, actually, that may have revealed another problem.

Fortunately, a call to the Engineer in Charge in the regional Field Office resulted in a direction to “just get everything fixed and send me a note.” The matter was closed.


In recent years, broadcasters have, unless they took part in the Alternative Broadcast Inspection Program (ABIP), begun to expect the occasional visit from an “Enforcement Specialist.” Generally speaking, the ES looks for Public File violations, EAS log violations, and tower fence and lighting violations, and not much more. Things easy to cite.

The perception in the industry is that this is basically a “revenue enhancement” operation and we are reaching a point where the broadcaster/regulator relationship is getting beyond irritating – and moving all the way to nonsensical.

Then there was the renewal application for radio stations a few years ago which included a question, essentially asking if stations had had any violations in the past seven years. More than a few stations answered in an excessively candid manner – and were fined for their honesty – until they learned the question only referred to violations for which the station was officially cited.


And now we have situations like the one involving KWVE in California reverberating around the country.

A botched EAS test sparked a complaint from a cable viewer, which led to a Notice of Apparent Liability (NAL) for $5,000 being sent to the station. To put it mildly: in the days since this NAL was announced, it has created an uproar in the broadcast community.

We are told that the situation is not final; the industry as a whole need not panic. It is “in process,” something that was sparked by the complaint and has to run its course. 

Yet, many have asked, “Is this some sort of strange manifestation of that stupid concept of the 90’s: Zero tolerance?”

According to staffers, it is true that once a complaint has been made, the FCC ‘must follow the procedures.’ On the other hand, many stations wonder why their complaints about stations that do not lower power at night, do not change DA patterns, fail to give IDs for days/weeks at a time, etc, are either ignored, or - at the very least - never acknowledged to the complaining station. Communication? The FCC?


Curiously, one of the key lines in the NAL refers to the “willful” actions of the station. A conversation with someone at the FCC elicited the comment that “willful has a legal meaning” that is different from its English meaning.

And this is supposed to be good for broadcasting?


What station, now volunteering its time and facilities to serve the EAS, will want to be an LP station, if they can be fined for a failed test? Why do anything more than the federally mandated minimum?

KWVE is not a station that routinely treats the test with carelessness, blows off a lot of tests, or botches many. Its CE is the chair for the local operational area’s EAS Committee. He trains his staff. His station has a good reputation. We understand a letter is being filed on behalf of all the state broadcast associations supporting KWVE, and asking that the fine be set aside, lest the situation be interpreted as a disincentive for stations to serve as LP stations.

Nevertheless, even if the NAL is dismissed, the legal costs for the station already exceed the potential fine.

Again, why be a part of the EAS if you are opening yourself up to this sort of NAL?


This needs to be clearly understood: while there are many well-meaning people working at the FCC, the way the institution treats local stations is often, at the same time, alternately a source of puzzlement, despair, and rage.

Someone at the FCC needs to blow a whistle and get everyone’s attention. They need to reassure the industry that the FCC does not view it merely as a source of fines to meet some assigned quota. And then the Commission needs to direct its field staff to act in harmony with that concept.

One step would be to be more open in explaining what Rules mean and what the regulators want to accomplish. In English.

Just try to get a clear answer in plain English about any number of what should be simple questions: station IDs, what day starts the week (for EAS), what to do about a co-channel station that does not lower power, and so many more. You go from office to office, get referred to the Rules, to your DC attorney, to your state broadcast association. “For legal reasons,” few are willing to give an answer in plain English.

This is not to ignore the highly complex, contentious stuff – there are hard to handle issues, often due to legal or political reasons. Lawyers are making piles of money batting around “wardrobe malfunctions.” Yet, so many of the small, daily issues could and should be handled without wasting hours and days of everyones’ time quibbling over the meaning of “is.”

There is clearly a place for fines and other sanctions. One does not have to travel very far to find stations out of compliance with the Rules in one measure or another. Sadly, for some stations, this is a long-standing problem – they cannot even pass an ABIP inspection; some inspectors even report being lied to regarding the correction of shortcomings during inspections.


The FCC has a lot on its plate. Broadcasting may be highly visible, but is only one of many concerns. So, no, we do not expect to see the FCC drop everything and give 100% of its manpower and attention to broadcasting. And lobbyists have a way of “taking over” many an issue. In some ways, that might just be one of the biggest problems!

But, with just a little communication, the broadcast community – great communicators - can bring workable solutions to the Commission, especially for daily operations in the technical and EAS areas.

We can bring this to a close by asking: How can broadcasters and the FCC draw closer? Can the previous collegial atmosphere between them be restored? Or have we reached a point where adversarial is the only word that will fit the relationship.

It is often observed that for a communication industry, precious little communication goes on. If it is at all possible, let us communicate.

If you have ideas on how to improve this situation, please send them on. Let us see if we cannot find a way to advance communication and improve the relationship between us all. At least, the attempt to communicate might start the process.

Barry Mishkind

Please click on “Contact” below, and let me know how you feel.


October 2, 2009

Hello! And welcome to the Broadcasters' Desktop Resource.

I'm just back from the Philly NAB Fall show, and thought I'd take a few moments to share my thoughts with you about the state of things broadcast.

You do not need me to know the bad news: the industry is in a bad place, and the pundits have been having many a field day. I'll leave it here: the industry has laid off - or chased off - more experience and knowledge than it realizes. 

At the NAB show, there were more exhibitors than I had expected. Still, reports say attendance was slightly lower than last year's event at Austin. The tech sessions varied widely, from under a dozen to about 50 for the IBOC power increase session. Not the best representation.

Still there is good news. Even amidst the wreckage, some stations are doing well - refocusing their efforts to improve content. Whether this will bring a lot of jobs back is not yet known, but it is encouraging to know that there are stations that remember the part about Public Service.

The technical community can help. Although we are not in a position to tell the owners what to do (at least in a format they will listen to), we can at least make the most of what we have. 

A few years ago, I wrote about something Frank Foti said to me that truly illustrates how many feel: radio engineers are a lot like train engineers. They can control the speed, but they cannot control the direction of travel. Some of us have long seen the train wreck that was coming, but had no way to avoid it. The best we could do was slow the descent into disaster.

If you are an engineer, be a master craftsman. You do not have to make things work on a two cent budget. But you can save money by looking ahead and at least warning management about obstacles on the tracks.

If you are in programming or management, do your best, too, to do more than "game" the PPM. You are the ones who can control/add/enhance content, the only thing that will make your station more appealing to listeners. 

In the meantime, share what you know. Share solutions here on the BDR. Share the BDR with your friends and co-workers. Please tell someone today about the BDR!

Thanks everyone!
Barry Mishkind



Home - Opt-in Newsletter - Tech Mailing lists - Contact - Help